Note: An appeal pursuant to s.45 (C2001/2221) was lodged against this decision - refer to Full Bench decisions [PR925566], [PR953368], [PR957746] and [PR961054] for result of appeal.
AUSTRALIAN INDUSTRIAL RELATIONS COMMISSION
Workplace Relations Act 1996
s.170CE application for relief in respect of termination of employment
Robert David Smith
(U No. 20854 of 1998)
Robert Edward Cusack
(U No. 20855 of 1998)
Gary Wayne Mannion
(U No. 20856 of 1998)
Todd Andrew Rogers
(U No. 20857 of 1998)
Alan McGuiness
(U No. 20858 of 1998)
Ron Frank Bettridge
(U No. 20859 of 1998)
Edward Hugh Appleton
(U No. 20860 of 1998)
Donald George Halverson
(U No. 20861 of 1998)
Bruce Charles Mitchelson
(U No. 20862 of 1998)
Garry William Barnes
(U No. 20863 of 1998)
Brian Peter Walsh
(U No. 20864 of 1998)
Morgan Kenneth Ray Lindley
(U No. 20865 of 1998)
Mitchell Joseph Albert
(U No. 20866 of 1998)
Athol Earnest Finger
(U No. 20867 of 1998)
Trevor Murray Kelly
(U No. 20868 of 1998)
Gabriel Pani Crichton
(U No. 20890 of 1998)
and
Pacific Coal Pty Ltd
COMMISSIONER HODDER |
BRISBANE, 9 APRIL 2001 |
Alleged unlawful termination - restructure and selection for retrenchment based on performance effectiveness review process - implementation and application of review process
DECISION
[1] This decision deals with sixteen applications filed under section 170CE(1) of the Workplace Relations Act 1996 (the Act) identified as R. D Smith and others, all of such applicants being members of and represented by the Construction, Forestry, Mining and Energy Union (the CFMEU). Each application expresses in its grounds that the respective individual's termination of employment as a coal miner related to retrenchment from their employment by Pacific Coal Pty Ltd (Pacific Coal) from its Central Queensland Blair Athol Mine was "harsh, unjust or unreasonable".
[2] The applicants named hereunder in alphabetical order, commenced employment at the Blair Athol mine on various dates and were terminated upon various dates, which resulted in an approximate number of years and months of respective employment up until the time of termination as outlined hereunder:
U Matter Number |
Name of employee |
Effective Date of Termination |
Approximate length of service |
20866 of 1998 |
Mitchell Albert |
17 August 1998 |
8 years, 4 months |
20860 of 1998 |
Edward Appleton |
24 August 1998 |
12 years, 8 months |
20863 of 1998 |
Garry Barnes |
17 August 1998 |
15 years |
20859 of 1998 |
Ron Bettridge |
19 August 1998 |
15 years |
20890 of 1998 |
Gabriel Crichton |
9 October 1998 |
10 years |
20855 of 1998 |
Robert Cusack |
24 August 1998 |
10 years |
20867 of 1998 |
Athol Finger |
4 September 1998 |
13 years |
20861 of 1998 |
Donald Halvorsen |
24 August 1998 |
13 years |
20868 of 1998 |
Trevor Kelly |
17 August 1998 |
13years |
20865 of 1998 |
Morgan Lindley |
24 August 1998 |
10 years |
20856 of 1998 |
Gary Mannion |
19 August 1998 |
10 years |
20862 of 1998 |
Bruce Mitchelson |
24 August 1998 |
15 years |
20858 of 1998 |
Alan McGuiness |
17 August 1998 |
18 years |
20857 of 1998 |
Todd Rogers |
17 August 1998 |
13 years |
20854 of 1998 |
Robert Smith |
17 August 1998 |
14 years |
20864 of 1998 |
Brian Walsh |
24 August 1998 |
18 years |
[3] In terms of the relief sought each application seeks the reinstatement of the applicant together with an amount in respect of the remuneration lost, or likely to have been lost because of the individual's termination of employment.
[4] The applications were joined with the consent of the parties and proceeded to an arbitral hearing before this Commission as presently constituted (this Commission) and were heard in conjunction and share common transcript and exhibits as well as individual and collective submissions.
[5] The following chronology in relation to these applications reveals the following. The applications were filed in July of 1998 followed by a conciliation conference under section 170CF of the Act which failed to settle any of the applications. This was followed by an Election to Proceed to Arbitration under section 170CFA which first came on for hearing on Wednesday, 11 November 1998.
[6] The proceedings, in the sense of hearings for the purpose of taking evidence, progressed to finalisation by way of final written submissions in reply on behalf of the applicants, forwarded under cover of correspondence on 30 March 2000.
[7] Further to this, on 21 June 2000 the CFMEU forwarded correspondence which raised matters by way of further submission arising from a decision of the High Court of Australia (the High Court) in Re Pacific Coal Pty Limited & Ors, Ex Parte Construction Forestry Mining & Energy Union and Anor [2000] HCA 34 - 15 June 2000 - S137/1998 (the High Court decision) which, it was submitted, were relevant to the considerations of this Commission in these matters.
[8] On receipt of such correspondence the parties were directed to provide any further submissions upon the issues raised by the CFMEU on 21 June 2000 as to such High Court decision, following which Pacific Coal provided submissions in answer and the CFMEU responded thereto on 21 July 2000.
[9] However, at the time such directions on this question were issued, it was indicated to the parties that this Commission had not formed a view as to whether or not any weight or reliance upon such submissions would follow.
[10] I note that the CFMEU, on behalf of the applicants raised submissions on the question of seniority and the incorporation of certain rights emanating from original letters of appointment of the applicants, which question was revisited within submissions originating on 21 June 2000 by reference to the High Court decision insofar as the question of common law contracts of employment and the incorporation of certain rights emanating from letters of appointment.
[11] In that regard I have considered the submissions of the parties as to the High Court matter referred to in paragraph 7 of this decision which, in summary, reveals that the more recent CFMEU submission implored this Commission to adopt the supposedly favourable inferences it draws but does not articulate from the paragraphs extracted from the High Court's decision that support the CFMEU's contention that the Reductions in Hand clause as at the time individual contracts of employment were entered into form part of those contracts.
[12] Set out below is a summary of the employer's response to the initial CFMEU submission and the CFMEU's reply thereto:
"The Union has selectively quoted from the High Court decision creating a misleading impression of the Court's deliberation. Moreover nothing in the Court's deliberation overturned current law already outlined in respondent's earlier submission. In that regard the wording in the applicants' contracts are insufficient to import award terms into contract which it is claimed therefore (according to current law) requires express words to achieve this result.
There were two proceedings before the Court which both rested on question of validity of section 3 of the WROLA Act. Therefore not open to applicants to claim the Court was in effect dealing with `the same factual matters'.
Gummow and Hayne JJ judgment does not alter current law and that the issue of importation of award provisions was considered by their Honours only in their attempt to characterise the `true effect of the relevant provisions of the WROLA' and therefore the issue only went to the enforceability of awards `not to the terms of individual contracts of employment'. The seniority clause relied on by the applicants is an example of the very style of clause their Honours conclude have no place in an employment contract because they cause rights or privileges to flow to organisations rather than to individuals. Most importantly, they argue, citing reference to Cliffe v Hoechst Australia Limited (an unreported Federal Court case), that it is necessary to distinguish between a contract which indicates that an award applies and binds the employer and one which includes specific rights and obligations that will apply to the individual contractual arrangement between a single employer and her/his employee. The respondents reinforce previous submissions that for the latter to occur it would require express words in each contract. In support of this proposition it cites the Industrial Court case of Moama Bowling Club Limited.
McHugh J's judgement does not disturb the decision in Cliffe. More particularly while he may approach the issue differently from Gummow and Hayne JJ the comments attributed to McHugh J in paragraph 120 need to be seen in the context of his deliberations on the competing contentions of the parties as to the effect of items 50 and 51 in part 2 of schedule 5 of the WROLA. The respondents also draw attention to what they consider the hypocrisy of the CFMEU's allegedly contradictory submissions to the High Court and to the Commission - in the case of the latter arguing that the effect of the removal of the seniority term from award would have been to remove it from individual contracts, while in the former arguing it remained in effect part of those contracts.
The reference to Kirby J's decision is irrelevant and in any event Kirby J's was a dissenting judgement it is unclear to the respondent why the applicants would seek to rely on it.
The High Court decision does not disturb the current law regarding importation of terms into a contract and the applicants failed to prove that the requisite express words existed in any of the applicants' contracts".
Submissions of CFMEU
[13] The CFMEU's further submission could be summarised as follows:
_ The High Court did nothing to alter the pre-existing law.
_ The applicants reiterated their earlier submissions that suggest if one analyses the elements of a contract and apply it to the facts in the situation then the Commission should be satisfied that the relevant terms (of the awards) were "incorporated by signature and reference into each individual contract".
_ A justification of the claim in the further submission of 21 June regarding the "same factual matters".
_ The applicants placed a number of cases before the Commission which it claimed purported to support their position regarding importation of the terms of the award(s) into their contracts of employment.
_ The employers have failed to refer the Commission to any case law to threaten the applicants' arguments that the present cases are all about the enforcement of individual rights by reference to past events.
_ No reference can be found to Cliffe v Hoechst Australia Limited in reported cases and the suggestion that McHugh J approved that decision was "puffery".
[14] Research conducted on these issues has, insofar as the relevant law and other considerations revealed:
Relevant law
[15] The current law is that in Byrne & Frew and Australian Airlines Limited (Byrne)1995 185 CLR 410. In that case the High Court determined that award provisions do not automatically become incorporated into contracts of employment and that the two modes of regulation are distinct. Wallace Bruce in Employee Relations Law (1998) at 64, summarises the principle determined in this case:
"The only way any other term of the award could become part of the contract is for the award to contain an express provision to that effect. The alternative will be for the parties to the contract to include a term in their contract that provisions of any applicable award are to become part of the contract. Such a decision will be based on the free will of the parties clearly expressed, and not derived from any presumption on their part. Otherwise, the two regimes remain separate, each governing an aspect of the employment relationship".
Other considerations
[16] If a choice as to one of the two interpretations of the applicability of the High Court decision is made then, it would be necessary to determine whether the "principles" contained in that reasoning constitutes binding authority. Set out below are a number of definitions believed relevant and useful as a reminder of the principles involved in making an assessment as to whether something is binding or not:
Ratio Decidendi |
- |
refers to the "argument or reasoning" (where such can be discerned) on which the Judge's decision is based. Thus any statement of the law logically necessary to that argument (as distinct from obiter dicta) is binding on a lower court as a precedent in accordance with the doctrine of stare decis (The CCH Macquarie Dictionary of Law, p142). |
Obiter Dicta |
- |
refers to Judge's statements on point of law which do not form part of the ratio decidendi and therefore are not binding as precedents (The CCH Macquarie Dictionary of Law, p121). |
Stare Decis |
- |
the legal doctrine of the binding force of precedent. |
The issues
_ Did any of the Judges in the High Court decision consider the issue of importation of award provisions into individual common law contracts of employment?
_ If "yes", did those considerations form part of the ratio decidendi or obiter dicta?
_ If it formed part of the ratio decidendi of the majority, can the current unfair dismissal cases before this Commission be distinguished from the High Court decision?
_ If the proceedings before this Commission are distinguishable, is the reasoning of any of the High Court Judges in the High Court decision persuasive authority?
_ If yes, what weight should be given to the Judge's reasoning?
_ If the authority is persuasive only, does it displace the existing law?
Conclusions
[17] It is apparent from the above summaries that Gummow J, Hayne J and McHugh J each considered to some extent the issue of the importation of award provisions into common law contracts of employment. The relevance on this subject is considered below.
[18] First, McHugh J's comments in paragraph 120 seem to be directly on the importation of award provisions into contracts of employment cannot, as his is a dissenting judgement, form part of the ratio. Morris, Cook, Creyke and Geddes Laying Down the Law, (1992) Butterworths at page 39 note:
"ratio decidendi is a proposition with which a majority of the court has agreed, it may be necessary to determine by a head count, what the majority thought were the relevant principles of law applicable to the case."
So, while McHugh J's reasoning in this regard may be of interest, it has no precedent value.
[19] Whether Gummow and Hayne JJ's consideration of the issue of the importation of award provisions into the terms and conditions of a contract of employment forms part of the ratio decidendi is less certain. As Chisholm and Nettheim Understanding Law, (1992) Butterworths at page 43 note:
"Sometimes it is difficult to say just what the ratio decidendi of a case is, as judgements are often much more complex than the ones we have considered, and in some cases the decision is made by several judges, all of whom give different reasons for arriving at the same result!".
[20] It appears that the issue was considered by their Honours but as illustrative of the character of the amendments. In this sense it does not form an essential stepping-stone in their reasoning and arguably is not "logically necessary" to their argument and as such is not binding on the Commission. Furthermore, according to Morris Cook Creyke and Geddes (at page 39) in circumstances when different judges arrive at the same conclusion via different arguments and rules, the individual judgments may be seen as persuasive but not binding.
[21] If this is the wrong assessment of the reasoning of their Honours, it seems the ratio would still be of little direct assistance to the applicants as their Honours do not find as a matter of fact or law that the "Reduction in Hands clause" was imported into the applicants' contract of employment, merely that it was commonplace for such provisions to be incorporated into contracts. Furthermore, as Pacific Coal noted, the clause in question is itself called into question as an example of a clause that if imported from an award, is one that should find no place in an employment contract as it purports to establish obligations on persons not party to the contract.
[22] In that sense the matters before this Commission can be distinguished from that of the High Court decision. Their Honours' references to the effect of the legislation on awards and award terms included in common law contracts of employment was made in the context of a theoretical analysis of the outcome or effect of statutory created rights in contrast to the application of a specific award clause in various contracts of employment entered into by various employee parties and the employer over a protracted period.
[23] In any event it would appear that McHugh J and Gummow and Hayne JJ are each of the view that award provisions are not incorporated by osmosis, there must be specific intent of the parties. So, even if this Commission were to arrive at an opposite view on the binding nature of their Honours' reasoning, the applicants would still need to establish that the parties intended to expressly incorporate some or all of the terms of an award at a particular time or, as varied from time to time. Even, if that hurdle is overcome, the relevant provisions may be in a form that cannot give rise to a contractual obligation between an employer and an employee.
[24] I am not persuaded that the law on importation on award provisions in common law contracts of employment has changed from that enunciated in Byrne's case. Certainly there is nothing in the various judgments of the majority that would warrant such a conclusion.
[25] In view of the above, whilst I accept the submissions raised by the CFMEU upon this question, I do not find that such attracts me to further consider the matters raised in my deliberations in this matter and intend to determine this matter on the basis of the submissions and evidence put to the Commission earlier in the proceedings.
Further submissions
[26] Further submissions were raised by Pacific Coal on 22 December 2000 and accepted by this Commission in relation to a decision of a Full Bench of this Commission in Dahlstrom & Ors v Wagstaff Cranbourne Pty Ltd (Dahlstrom) [Print T1001].
[27] It was submitted in support of having this Commission accepting such further submissions that:
"(a) the case deals specifically with the provisions in Sec 170 CE of the Workplace Relations Act 1996 in the context of the selection by an employer of employees for redundancy. . . .;
(b) The decision is one of the Full Bench of the Commission and accordingly is binding upon the Commission in determining the current matter;
(c) The decision espouses an important principle which was raised specifically by the respondents in various parts of their closing submissions delivered in February 2000. Hence,it involves consideration of precisely the same matters which the Commission is called upon to consider in the present case".
[28] Appropriate consideration has been given to what the parties had to say upon this in the overall consideration of the authorities presented by the parties.
Witnesses for both parties
[29] In addition to the evidence of the sixteen applicants who were represented by Counsel, evidence was also called from Mr A. Vickers and Mr R. Barker, both of whom are officers of the CFMEU. Evidence was also called from a Mr M. Pidgeon, a mine worker at Blair Athol Mine who had signed an Australian Workplace Agreement (AWA) on 7 January 1999 and a Ms J. Hoch who was a former administrative employee at the mine.
[30] The applicants also called two expert witnesses, firstly Ms Martha Knox, an Industrial Psychologist who gave evidence about Performance Appraisal Systems (PA's), whilst a Mr John Heath, a handwriting expert, gave evidence in relation to what was to become known as "Joe's Book", (Exhibit CFMEU 84 at p 301).
[31] The applicants worked in the following identified areas of the mine and were called to give evidence in the following order:
Order |
Employee |
Identified Area |
(1) |
Mr Mannion |
Production - Coal PreparationPlant |
(2) |
Mr Halverson | |
(3) |
Mr McGuiness |
Maintenance - Supply |
(4) |
Mr Walsh | |
(5) |
Mr Crichton |
Production - Pit Operations |
(6) |
Mr Rogers |
Production - Mine - Services |
(7) |
Mr Appleton | |
(8) |
Mr Lindley |
Production - Overburden |
(9) |
Mr Kelly | |
(10) |
Mr Finger | |
(11) |
Mr Mitchelson | |
(12) |
Mr Cusack | |
(13) |
Mr Bettridge | |
(14) |
Mr Albert | |
(15) |
Mr Smith | |
(16) |
Mr Barnes |
[32] Pacific Coal, also legally represented, called evidence from nineteen witnesses who comprised supervisors, superintendents and management staff and an expert witness in PAS's, a Ms Kay Arnold. These witnesses were called in the following order:
Name |
Title |
Mr Paul McCrae |
Manager Employee Relations |
Mr M. Keag |
Superintendent-Pit Operations |
Mr Joseph Riordan |
Manager Maintenance |
Mr A. Crooks |
Supply And Services Supervisor |
Mr P. Fox |
Superintendent Mobile EquipmentWorkshop |
Mr Simon Prebble |
Superintendent Coal plant |
Mr S. Edelman |
Superintedent Overburden |
Mr L. Gardner |
Supervisor-Overburden |
Mr Michael Duncan |
Operator Mining Services |
Ms P.K. Arnold |
Psychologist /Expert Witness |
Mr Ian Thompson |
Superintendent Mining |
Mr W. Clein |
Pit Supervisor |
Mr M. Dickinson |
Coal Plant Supervisor |
Mr Pat Campbell |
Mining supervisor |
Mr Stuart Brown |
Pit Supervisor |
Mr J. Richmond |
Staff Supervisor |
Mr Scott A. Browne |
Mining Services Supervisor |
Mr Darren Yeates |
Manager Production |
Mr Rod Bates |
General Manager |
Background
[33] The enterprise operated by Pacific Coal at which the applicants were employed as coal sminers is an open-cut coal mine facilitated by an associated coal preparation plant and is located near the town of Clermont in Central Queensland.
[34] In gaining an understanding of the background to these matters the following extract from the Pacific Coal Year 2000 submissions which, whilst not the total comment upon this question which I reproduce later, is helpful in gaining an understanding of the inherent issues:
"During 1997 Blair Athol Coal undertook a fundamental review of its operations aimed at reducing operating costs and increasing productivity. The organisational review determined that the Mine was overmanned and accordingly it was planned to reduce total employee numbers by approximately 80 to 100. Details of this plan were communicated to employees and the unions on 13 November 1997. As part of this announcement the Company advised that it would be offering voluntary redundancy packages to employees identified as having no role after the reorganisation. Again the Company emphasised the importance of employee performance in determining who would remain following the restructure.
. . . . .
As part of the Company's productivity improvement plan it introduced a Personal Effectiveness Review (`PER') for all employees designed to identify areas of improvement. The PER was designed to be a simple system covering four areas which would be readily understood by the workforce, namely safety, teamwork, skills and personal effort. Employees were encouraged to actively participate in the review process.
The Unions at Blair Athol did not embrace the PER process, with the CFMEU at first discouraging employees to attend the PER interviews, and then moving to a position where it was left up to their members to decide whether they wished to participate. At the same time the CFMEU advised its members that it believed seniority would remain an award obligation and accordingly advised employees that the Company could not reduce workforce numbers based on performance measures.
It cannot be suggested that any of the Applicants were not aware of the importance of their performance if they wished to retain a role at Blair Athol. This was a constant theme during 1997 and 1998 as the Company moved to improve productivity and restructure for efficiency".
[35] Further, Pacific Coal submitted within its Year 2000 submissions consistent with the above that the terminations were the result of genuine operational requirements and that the selection of the applicants for redundancy should not be set against the Performance Effectiveness Reviews (PER) used to rank employees against a range of criteria as this was not the determinant factor and was only a part of the reasoning applied to the applicants being selected for termination by being made redundant.
[36] This is supported by the following extract from Pacific Coal's submissions:
"These terminations are the single change flowing from the restructure the Commission is concerned about in these proceedings. The company set out about devising a method by which it would select which 16 employees to make redundant. The method that the company chose to make this selection is at the heart of what the Commission must decide in this case. There is no evidence upon which the Commission can find that the decision to downsize was not open to the company; clearly the company was entitled to decide to restructure its operations, to achieve greater efficiencies. Nor can the Commission make any adverse findings about the voluntary redundancies.The sole matter to be determined in the proceedings is whether, in terminating the employment of the 16 applicants, the company acted harshly, unjustly or unreasonably".
CFMEU's rebuttal of this
[37] What the CFMEU had to say in this regard runs counter to this by way of the following extract from the Year 2000 submissions made on behalf of the applicants:
"Systems And Individual Attack
16) The submissions initially deal with the eleven (11) grounds on a systems or overall basis. The primary submission is that the PER system and the so-called retrenchment processes, as they were designed and applied at BA to the P & E workforce, had so many unfair pitfalls and were so flawed that every applicant is entitled to succeed before the AIRC. The applicants have shown by the systems' attack that each applicant's termination was harsh, unjust or unreasonable.
17) Additionally, or in the alternative, a consideration of the evidence for each individual applicant establishes that the way in which the PER system and/or selection for redundancy processes were applied unfairly to him resulted in each applicant's termination being harsh, unjust or unreasonable. The submissions set out below deal with the some of the salient evidence for each individual applicant".
[38] Both of the parties went to considerable detail and volume in their submissions detailing significant aspects of the evidence presented with both parties referring to numerous authorities in support of their respective positions .
[39] I do not however intend to specifically refer to all of such evidence or submissions within this decision however where appropriate, I intend to refer directly to evidence and/or submissions where it is pertinent and helpful in constructing this decision.
Submissions made on behalf of the applicants
[40] The Year 2000 submissions of the CFMEU contained the following extract of grounds for relief.
"15) The applicants have previously indicated that they rely on any one or more of the eleven (11) grounds for relief. Illustrative evidential example(s) are provided for each ground in this introduction in order to demonstrate what a compelling case has indeed been made out by the applicants. The eleven (11) grounds are as follows:
a) The applicants in the performance effectiveness review (PER) process were not accorded procedural fairness or due process. Ms Arnold, the employer's expert, admitted it is accepted that you can't have a fair performance appraisal (PA) system without both due process and accuracy. This is not an elusive distinction - it is just the accepted convention: XX2713. After conceding she did not know factually what was the position at BA (based on what she was briefed with by the employer for preparing her report), Ms Arnold in cross examination was then asked questions based on the actual evidence adduced from the employers' witnesses, and she admitted such evidence meant in terms of due process for a PA that the BA position was grossly unfair and/or fundamentally unfair. Thus, it is submitted each applicant is entitled to succeed, without more, on this ground alone.
b) Secondly, the employer failed to make an objective and fair ranking selection for redundancy where each selection purportedly related to the conduct and capacity of the employee. Putting it another way, there did not exist a valid reason for the termination where the employer alleges it related to the capacity or conduct of the employee (s 170CG(3)). Take, by way of example, Mr McGuiness who was considered by his supervisor, Mr Crooks, to always be a good worker who was a solid performer: XX46 L21?. Indeed, he was considered to be very-very good and that was why Mr Crooks attempted to get him to mining: XX59 L6?. The reasons why he received a lower rating in the PERs and the `Future Requirements' was he said things like `Hang on, I want job security. I'd rather we didn't use contractors. Let's do the work ourselves' (XX47 L28, 50 L21, 61 L16) and he was expressed a view for PER1 about insisting on sticking to the work model where by, under a prevailing agreement with the employer, his welding skill was quarantined (XX48-49). Mr McGuiness would have got 2 out of 3 at least for personal effort and skills other than his views on contractors and quarantining of skills: XX51 L20. The employer, including people like Mr Riordan and Mr Fox, considered these to be union objections: XX59 L 16. Mr McGuiness, who was considered good and solid and who Mr Crooks wanted to keep at BA, got marked down for expressing a view in an Australian workplace in 1998: XX58 L18. Mr Crooks was unable to point to one example where Mr McGuiness by expressing his view worked any less productively at BA: XX58-59. Mr Crooks also rejected the allegations (made by Mr Riordan) that Mr McGuiness was unproductive and a slow worker: XX46-47. Even Mr Bates had to admit that the allegations of Mr Crooks about Mr McGuiness, namely, Mr McGuiness said to the effect `Hang on, I'd like job security. Don't contract out my job, let's do the work ourselves' and also `Don't deal with me one-on-one on an issue like quarantining of skills in the work model. Negotiate through my union', would never constitute a reason to be considered, or described as, a poor performer: XX4472 - 4476.
c) Thirdly, other then for Mr Albert, the termination of employment of the applicants was illegal and thereby harsh, unjust or unreasonable, in that each termination was in breach of a seniority term in the individual's contract of employment. The colour of the employer's conduct can be gleaned from how it asked Messrs McGuiness and Walsh to sign away their legal entitlement to seniority (Mr Thompson XX2939 L20) and the employer was actively pursuing people to sign AWAs who were low on the seniority list (ex CFMEU84). This was where there had been an incorporation of seniority into the individual contracts of applicants by the following means:
i) Other than for Messrs McGuiness and Walsh (for whom any letter of appointment has not been located), it has been proved that seniority was incorporated into an individual's contract expressly by means of the employer's written offer of employment.
ii) Seniority was incorporated into each individual's contract by custom or usage in the black coal industry in eastern Australia. The evidence of Mr Vickers was never challenged on the industry position.
d) Fourthly, there has been an employer preference to AWA employees over union employees. See the above evidence under the heading `CFMEU MEMBERSHIP REDUCTION & HEAD STARTS FOR AWAS'.
e) Fifthly, there was a difference in treatment in the financial package for voluntary versus forced redundancy, namely, about $30,000 less. The material consequences of a termination of an employee's employment may be intimately connected with the validity of the reason for termination - it may add to the soundness if the employer voluntarily and adequately compensates the employee for the loss of his/her job. It should be noted Messrs Manion, Betteridge, Appleton, Rogers, McGuiness and Walsh kept working in their same areas throughout the employer processes.
f) Sixthly, there was a harsh effect on the personal circumstances of an applicant as an individual employee in terms of his personal, social and economic situation. Mr Albert suffered injuries from a road accident and also was going through a marriage split up. Despite the employer being of the view that there was an excess of P & E employees at BA since at least early 1997, it refused to give Mr Albert unpaid time off for the purpose of resolving his personal problems and where it knew these problems were having an impact on his work performance.
g) Seventhly, there exists a legitimate expectation that an employee would be employed by the employer for the life of the mine due to various employer representations.
h) Eighthly, it is not conceded that there was no valid reason for the termination related to the operational requirements of the employer's undertaking (170CG(3)(a)). The expression `operational requirements' is a broad term that permits consideration of many matters including past and present performance of the undertaking, the state of the market in which it operates, steps that may be taken to improve the efficiency of the undertaking by installing new processes, equipment or skills, or by arranging for labour to be used more productively, and the application of good management to the undertaking.
i) Additionally, an order for a remedy under s 170CG(1) means the effect of the order on the viability of the employer's undertaking must be considered (s 170CH(2)(a)). As seen above, the BA resource is a dream resource and the only question is how much money it will make.
j) Ninthly, the employer should have called for volunteers right across the work force in order to meet its targeted number of redundancies (amended contention 9 T24). There is evidence in the present cases of a person or persons in a category of available volunteers who could have been selected instead of the applicants: see, for example, Mr Barnes (ex CFMEU50 sup para 37) the list of 9 employees who were refused VER by the employer, and Mr Thompson admitted that `Maybe' some of the applicants might still be there if other people volunteering to go were accepted by the company (XX2954 L26).
k) Tenthly, the employer was avoiding the reduction in hands clause in the collective agreement (amended contention 10 T25).
l) Eleventhly, the employer desired to get rid of the particular clause 20 award or in other words the particular collectively bargained instrument (amended contention 11 T25). As seen above, the employer's ruthless attitude is evident where Mr McCrea in examination in chief said `But we wanted to make sure that this document wasn't going to ever restrict us if we ever thought of a way of getting round it.'."
Summary of submissions generally
[41] The following is a summary of and/or reproduction of the Year 2000 submissions on behalf of the applicants and, where appropriate, reference to the evidence of the witnesses for both parties. This commences with an introduction which talked about the evidence supporting the financial soundness of the mine and that the mine could be described as having mining conditions amongst the best in the world.
[42] The submissions in support of the abovementioned eleven grounds attack the process used to select the applicants for redundancy/termination to the extent that it was alleged that the evidence presented as to the application of the PER used to select the applicants reveals a flawed and manipulated process.
[43] This allegation was said to be supported by submissions that steps were ultimately taken by supervisory, superintendent and management staff designed to ensure by way of manipulation of the PER process used to rate the workforce in descending order, placing the applicants as the lowest ranked employees within the mine workforce
[44] The design of this style of manipulation ultimately, it was submitted, was to ensure the selection of the applicants for termination by way of redundancy as opposed to others who had signed an AWA.
[45] Those persons having signed an AWA were said to have been favoured and advantaged against the applicants by Pacific Coal in part because of their refusal to sign an AWA and maintenance of CFMEU membership or affiliation aligned with an adherence to collective negotiations and what they believed were their industrial rights under a collective agreement.
The standing of respective witness evidence
[46] As far as the evidence of the applicants generally and, in particular to the abovementioned allegations, as opposed to the evidence of the Pacific Coal staff witnesses, the CFMEU submitted that this Commission, having observed the demeanour of these witnesses and alleged inconsistencies in the evidence of Pacific Coal's staff witnesses should, in all instances, have a preference for the applicants' evidence.
[47] Based upon the above and reflective of the Year 2000 submissions made on behalf of the applicants, I have summarised by way of the following, the allegations made on behalf of the applicants alleging that the assessments of the applicants carried out by the relevant supervisors reveal a flawed process .
[48] Such flawed process, it was submitted, contained but was not limited to the following elements which were said to support the claims that the applicants' termination, using the results of the PER system to select them for redundancy, was harsh, unjust or unreasonable and not reflective of a valid reason and that it therefore denied the applicants a "fair go all round".
[49] In reflection of the above reference as to a flawed process, I note in the Outline of Submissions by Pacific Coal dated 3 February 1999 (Exhibit PC21) that it was submitted that Pacific Coal had informed the employees of the importance of the PER process and that it would be one of the factors taken into account in selection for any future redundancy.
[50] This allegedly led to the adoption of a PER system by arbitrary methods denying the applicants procedural fairness in that neither they nor the CFMEU had a voice in the development of the PER system.
[51] Aligned with this, the Year 2000 submissions upon examination of the evidence was said to reveal a failure to properly explain the requirements of the system to the applicants and disregard for, the application of, and research of the literature of acknowledged authorities in the field useful in developing a PER system capable of ensuring a fair and transparent PER process.
[52] A further criticism was an alleged lack of proper and appropriate training of supervisory staff responsible for the application of the PER system insofar as the recognised training in this area. It was submitted that whilst the supervisory staff were given some training on how to provide feedback to employees and to conduct PER sessions there was no training on PA's feedback and participation offered for subordinates (see evidence of Mr Gardner and Mr Duncan respectively at Transcript pages 2571 and 2651).
[53] The result of this was described as a failure to ensure a fair assessment regime with checks and balances which would result in a transparent system capable of withstanding scrutiny to the extent that an individual's assessment could be observed as fairly arrived at.
[54] In support of the above allegations, issue was taken with a document described as an advice to "All Overburden Employees" dated 5 August 1997 under the hand of the then Overburden Superintendent a Mr S. Prebble (Annexure B to Exhibit CFMEU 23), sent out six weeks after the first of the reviews of staff in the PER 1 Review period had taken place.
[55] This was received by nine of the applicants who happened to work in that area and was described as the first time Pacific Coal had attempted to explain to any of the Production Engineering workforce the "why and how" the PER's will be carried out. Attached to such advice was what was described as a copy of a PER document that would be used to record the one on one discussion intended to give an idea of what was involved in the process.
[56] However it was pointed out that the Overburden area waited until the end of October 1997 to receive the employer's completed individual PER 1 document which meant that approximately two months of PER 2 period was left or alternatively ten months of the PER process had elapsed and the applicants were still none the wiser about what was required of them in such process.
[57] A further criticism was an alleged failure to involve, if not all of the applicants, the greater percentage of them in training about the process as opposed to non CFMEU members or AWA participants, and/or by way of a briefing provided by Pacific Coal in Emerald at a three day course from 8 September 1997 called "Effective Workplace Program".
[58] Mr Appleton, one of two applicants, attended the briefing and gave evidence about this. The effect of his evidence was that nothing in the course touched upon the PER system, nor for that matter was any coaching provided by their raters as to what was expected of them in and during the review process. This point was said to have been corroborated by a Pacific Coal witness Mr Duncan at Transcript page 2651).
[59] Alleged preferential treatment of employees engaged under the terms of an AWA was described as up to $10.000.00 per year financial advantage as opposed to those employed under the collective arrangement, enhanced training to acquire skills in production work roles resulting in better scores for ranking purposes, preferential treatment in providing information and advice as to the PER system and more liberal rating results as opposed to the applicants, allegedly said to have been a reward to such persons for having signed an AWA.
[60] The submissions were also critical of the process of selection as to the use of a retrospective review process as opposed to one in advance of its implementation rather than by way of the initial six month period from 1 January 1997 to 30 June 1997 (PER 1) including, in some instances, retrospective review back to 1993 and 1994 for the first performance review for assessment purposes. This retrospective process involved the use of impirical information which was based upon alleged inaccurate or improper information said to support the flawed process allegation.
[61] At its end, this initial period for PER 1 involved a one on one session between the rater and the employee which the applicants, given that attendance was voluntary, collectively chose not to attend. This was never revisited by Pacific Coal with the applicants collectively or individually insofar as PER 1 was concerned, even though this was accepted as a learning tool for the employees. (Transcript, Mr Paul McRae, pages 1288 -1289).
[62] The preparation of the supervisors responsible for ratings for PER 1 was allegedly inadequate caused by such supervisors not being in possession of what was described as the "4 criteria" intended to be used to rate employees at the time they conducted the PER 1 reviews.
[63] This was said to be vindicated by what the CFMEU expert witness Ms Knox said in her report (Exhibit CFMEU 55) and referred to within the Year 2000 submissions as set out hereunder:
"One way of estimating fairness is to ask whether the performance appraisal system is structured in such a fashion that all employees would have been assessed in a consistent fashion. One way of assessing potential for consistency is to ask whether a performance appraisal system is sufficiently structured so as to eliminate the possibility of variation amongst assessors".
[64] Further periods of assessment from 1 July 1997 to 31 December 1997 (PER 2) and 1 January 1998 to 30 June 1998 (PER 3) were alleged to have suffered from similar and other flaws in the process used. An example of this was submitted as the applicants having been marked down in their rating results for the taking of genuine sick leave or personal unpaid family leave, and the non-agreement to perform duties contrary to award entitlements.
[65] Included in the above scenario were allegations of inappropriate work practices said to have been carried out by applicants which led to lower ratings which were said to have never been substantiated, or by not agreeing verbally with contracting out of work performed by
[66] permanent employees, or stating opposition to acceptance of an AWA but not by any other act or by allegedly being quiet at safety meetings, all of which it was claimed, led to lower ratings.
[67] Further, it was alleged that Pacific Coal failed to inform the applicants of the reasons for their ratings in each review period demonstrated by either non-existing diary notes held by the raters or a refusal to provide such notes relating to good or bad work behaviours for feedback to the applicants as an aid to their performance.
[68] The extent of this, it was submitted, was that the applicants were unaware of the method and information applied by each assessor and the accuracy of same in arriving at their individual rating . This was said to have diminished the applicants' capacity to have been in a position to challenge such rating by way of the appeal provisions provided for that purpose because of no opportunity being provided to examine such records.
[69] Attention was drawn to evidence which was said to reveal the failure to provide factual examples of alleged incidents which led to lower ratings of the applicants, aligned with the failure to provide the applicants with the results of their PER's. Attention was also drawn to the failure to provide an interview to Mr Garry Barnes, in view of his request to tape record his PER 2 interview for the sake of accuracy.
[70] The inability of some raters and those responsible for qualifying the ratings to accurately rate an applicant in view of the applicant being on night shift and the rater and those responsible for qualifying the ratings being on day shift or, alternatively, in having limited opportunity to observe an applicant because of job location logistics was also raised.
[71] The verification, standardisation, or normalisation process used by Pacific Coal was described as inadequate to the extent that the process used had the capacity to throw up inconsistent scales of comparison with the result being a replication of the alleged original biases that team leaders had come up with.
[72] It was alleged that there was a failure to provide PER interviews to applicants prior to a Production Matrix having been completed on 22 June 1998, with such matrix being used and applied to the finalisation of the selection of the continuing workforce and not disclosed to the applicants.
[73] This process was said to have been fundamentally flawed to the extent that the applicants were always intended to be rated low in view of a hidden agenda which included their names having been entered into what was described as a `black list" with reference to the applicants having been identified as "still to go". The existence of this black list, it was submitted, ensured that the applicants were identified as those still employed and still to go and that such black list was never revealed to the applicants or the CFMEU prior to their termination.
[74] In addition to this allegation it was submitted that Pacific Coal failed to respond to a Summons which sought the production of ranking lists and that the use of coloured lists (black, blue, brown and red) only revealed and produced after Ms Hoch, a former administrative employee, gave her evidence on 2 July 1999 and that this non-production was contrary to the terms of a Summons to Produce issued by this Commission.
[75] However it was alleged that some employees (obviously other than the applicants) who were initially on this black list were able to get themselves removed from the black list by signing an AWA which led to what was described as "massaging of scores".
[76] This black list was said to have been used as the identification of the applicants during the selection process under the PER system as those employees who were targeted by Pacific Coal to be made redundant. The status of the black list was said to have been known to those responsible for the ratings to the extent that this was said to have had an impact upon their impartiality when rating the applicants. It was submitted that the end result was that those who were identified and remained upon such black list were targeted for termination by way of redundancy even though the applicants were not aware that this was a function of the PER system.
[77] This, it was alleged, ensured that those who remained upon the black list were ultimately given rating marks ensured to place them in ranking below any other employee at the mine during the period the PER process was applied, given that such ratings were to rank and identify the lowest ranked employees who were to be made redundant.
[78] The ratings for each applicant prior to PER 3 basically meant that applicants were rated in such a way that it was submitted that it would have been near impossible for them to have achieved a rating in the period for PER 3 to the extent that they could have achieved a position above any other employee. (Refer Transcript page 2654 to 2656, cross-examination of Mr Duncan).
[79] This allegation was particularly raised about those who had signed an AWA irrespective of whether such persons had previously been named on the black list. That action was personified as Pacific Coal failing to make an objective and fair ranking selection for redundancy and not according the applicants procedural fairness or due process and that the evidence of Ms Arnold (the expert witness for Pacific Coal) under cross-examination at Transcript, page 2713 supported such claim.
[80] It was alleged that all of the applicants were members of the CFMEU and that part of the process applied by Pacific Coal was to diminish CFMEU influence on the site either by way of having CFMEU members accept the terms of an AWA, or to take a redundancy package which became less attractive if accepted after a certain date.
[81] The actions of Pacific Coal by its alleged attempts to deny that such black list existed or had existed and its alleged resistance to producing such list, even though same was sought by Summons to Produce, was said to be supportive of such allegations. The acknowledgement of the existence of such list when the document was revealed as having been in existence in the relevant period by a former administrative employee, Ms J Hoch, was said to show that Pacific Coal had something to hide about the list.
[82] This evidence, it was alleged, led to the production of other lists which were described by Pacific Coal in its Year 2000 submissions as:
"Because numbers needed to be reduced by about a third, colour coding was introduced to differentiate between groups of employees using the colours of blue, red and black, and in maintenance, brown".
[83] Much has been said about the black list upon which ultimately the applicants' names were the only names recorded. As far as the applicants were concerned this, it was submitted, effectively meant that having their names placed upon such list placed a stigma, so to speak, upon them with those responsible for not only carrying out their individual assessments but also the management staff when their results under the PER system were confirmed. The extent of this, it was said, meant that the system, in a collusive manner, was manipulated to ensure that the applicants were selected for redundancy.
[84] The following extract from the CFMEU submissions goes to this point:
"BLACK LIST STILL TO GO
12) The applicants' also rely on the fact that the employer used black list which was created and relied upon by it in a covert fashion as a reference point for selection for retrenchment. For current purposes a selection of the evidence about the `black list still to go' includes:
a) Before PER1 was even done, a list was completed on the whiteboard by the employer with Superintendents and Supervisors `all expressing their personal feelings' and it was `only just a gut feeling of people on what they believed.' It turned out that `those who, under the gut feeling, ranked the lowest employees were given the lowest scores in the PER': XX2585-2587 Mr Gardner. It should be noted that the employer has not produced these lists. (My emphasis).
b) On 2 July 1999, Ms Hoch was called and her statement said in para 13 ex CFMEU90 `Black meant they did not have a job anymore.' Exhibit CFMEU88 established in the proceedings for the first time that two of the applicants, namely Mr Appleton and Mr Rogers, were on the `black list still to go'. Despite the compulsion of law in the form of a summons to produce, the employer failed to produce any black or blue lists until they were exposed by the evidence of Ms Hoch and ex CFMEU88.". (My emphasis).
[85] The existence of and knowledge of the black list to those responsible for rating the applicants and the raters' understanding of the implication of this for the individuals upon such list is exampled by the following extract of the evidence arising under cross-examination of a Pacific Coal witness:
"c) Mr Gardner:
You will have to answer my question. You know there was a black list at Blair Athol of those who were targeted to go, don't you?---There was a list, yes.
And consistent with the evidence this morning when I asked you about your understanding of a black list, that meant those the company were going to forcibly retrench, doesn't it? Yes or no?---Yes.
And there was no bones made about it that there was a black list at Blair Athol of those who were going to be forcibly retrenched, wasn't there?---That's the people that they wanted to get rid of, yes: XX2521.
d) If an employee on the `black list still to go' did not accept voluntary redundancy, when the time came, he was going to be forcibly retrenched or sacked. This was made clear by Mr Bates at meetings of supervisors at the start of 1997: Mr Campbell XX3070 L26 - 3071. In Mr Campbell's area, no one got off this list and they were all sacked: L15.
e) The `blue list' meant Mr Campbell one colour was for those selected to be retained , that is kept, at the mine: XX3066 L21.
f) On 21 October 1997 at the third quarterly review meeting of managers it was discussed that there was to be a meeting organised with Supervisors And Superintendents. It was to be communicated to everyone `Rating Black List are very likely unlikely to achieve 7 or 8 (ie `Meet expectations')'. Neither Mr Thompson or Mr Campbell were willing to deny the original entry of `Black List are unlikely to achieve 7 or 8 (ie `Meet expectations')' was communicated to them. . . . . ".
[86] The Year 2000 submissions highlighted the convergence of thought of Ms Knox and Ms Arnold, the expert witnesses called respectively by the parties, and exampled by way of the following:
"13) It should be noted that the implications of these lists for the unfair operation of the employer's selection systems were as follows:
a) Ms Knox, the practising psychologist called by the applicants, said (ex CFMEU55 at p 4) said `If knowledge of future retrenchees' identity was widespread, then this may have undermined those employees' chances of getting a fair and unbiased assessment during the second, third and fourth PERs. This issue needs more detailed examination to see how widespread such knowledge was' (emphasis added). Later in her report (at p 28), Ms Knox also said `This bias is apparent in that assessors seemed more likely to note down what was wrong with these particular employees rather than respond to descriptors where the employees performance was satisfactory. This may have resulted in an unduly negative view of these employees'. This issue has been examined in more detail by the applicants from the records produced under compulsion and in cross-examination of the employer's case. It can be safely concluded that the knowledge was widespread amongst those responsible for rating the P & E workforce, namely, Supervisors and the management stratum above that level, and the bias and prejudice has been proved to have operated in practice. By way of example, the `21 October 1997 communication' in `Joe's Book', as referred to below, provided powerful evidence of the unfair and biased nature of the employer's PER system
b) Ms Knox also said (at p 4) `This also raises a concern that the decision to retrench was based on the results from the first PER. It should be born in mind that this was also the first time that team leaders were asked to use such an instrument. There is an issue over whether the accuracy of those retrenchment nominations would not have been improved by selecting employees on the basis of second and third PERs' (emphasis added). The real nature of this concern is demonstrated by the fact that 12 of the 16 applicants were on the black lists no later than after PER1 (about 11/97). Further, a number of applicants were told by various stratum of management in November 1997 that they had no role in the future operation of BA. Moreover, PER1 was supposed to have been a voluntary process.
c) Ms Arnold accepted if the 21 October 1997 communication was a decision it would be unfair and, furthermore, the communication would colour, in the sense of potentially biasing or prejudicing, the views of supervisors and superintendents (XX2816). (My emphasis).
d) Applicants had already been selected for redundancy prior to 1 July 1998 in contravention of the `reduction in hands' clause in the applicable award and/or in contravention of an earlier `reduction in hands' clause expressly incorporated in an individual applicant's contract of employment.
e) P & E employees had already been selected for retention prior to 1 July 1998".
[87] In support of what was alleged directly before, further issue with the information provided as to the PER system and dissemanation of such information and allegations as to denial of procedural fairness is outlined by way of the following:
"a) The `GM TEAM MEETING STRICTYLY CONFIDENTIAL (Not for distribution)' minute dated 24 March 1997 states `We need to decide what behaviours we want and push to achieve those behaviours' It follows that 3 months into the PER1 review the senior management team at BA did not even know what behaviours they wanted.:
b) Mr Crooks, the supervisor, admitted they had no idea about the criteria to be used for PER1 and they were not given any notice of what standards were to be used.
MR DOCKING: In your first statement, I'm taking you to paragraph 25 page 3. It was in about late July 1997 you did the first PER for Mr McGuinness, wasn't it?---I believe so, yes.
Before late July 1997, you hadn't told him what the four headings were in the PER and what all the dot points were under each of those headings, had you?---No, not-don't believe so, no.
So for his first review period, Mr McGuiness had no idea about what criteria were being used for the performance effectiveness review, did he?---No, probably not. The initial review was - that's where I believe we're at now and - so that was the first one.
And that was done retrospectively, that is, when the PER was done by you, it looked backwards to a review period of six months which had finished already?---Yes, I think that's right, yes.
So no notice was given to people like Mr McGuiness or Mr Walsh about what standards were to be used in that PER document, were they?---Not directly by me, no.
Because in the area Messrs McGuiness and Walsh worked, they were never given a memorandum by the company before the first PER which explained the system were they?---I don't know about that.
Well, you never gave them one, did you?---Not to my recollection, no: XX1850 L8 (emphasis added).
c) Mr Gardner:
You didn't have it before Mr Keag sent it out (Mr Keag's memorandum dated 21.7.97), did you?---So it means you didn't have this set of criteria with all the dot points to counsel and coach people like Mr Cusack during - I'm talking about PER review period 1, did you?---Yes. We didn't have the guidelines then, no.
So you couldn't have coached him about the matters in these, could you?---No.
That applies to all the people in the overburden area, doesn't it, given you didn't have the guidelines about what are the dot points on the form in front of you?---Yes. I'm not sure what you're getting at.
Well, you couldn't coach them if you didn't know what the dot points were. That's right?---Possibly, yes.
Well, that's right, isn't it. Not possibly; it's right. Yes or no?---Yes: Mr Gardner XX25571 (emphasis added).
d) Mr Duncan:
So let's go to the next page which is headed Mid Year Review. Do you see it has `Safety, personal effort, skills and team work' and dot points under each of those?---Yes.
The first time you saw those headings with all the dot points is when Mr Prebble spoke to you in an office about how to do them?---That's right, yes.
So you obviously weren't coaching or counselling about those matters before you got the four headings and the dot points?---No. I wouldn't have been, no.
Were you told to coach and counsel people on those dot points and headings after Mr Prebble showed you the form?---I wasn't told to, no: Mr Duncan XX2651 (emphasis added).
And later as to the 8 criteria in the so-called retrenchment process
I'm trying to get at when you first saw the criteria?---Was when I walked in the room.
The didn't give you any advance notice for you to prepare at all, did they?---No, not really.
And you're aware, are you, that some of your comments you put in the third PER are quite inconsistent with the ratings they got out of the 1 to 5?---Well, again, I'd have to say I can't remember because I can't even remember doing the ratings let alone what's in them: XX2651 (emphasis added).
20) Thirdly, Mr Prebble's memo dated 5 August 1997 to `All Overburden Employees' (ex CFMEU23 Annexure B) was sent over 6 weeks after the finish of the review period for PER1, ie after the first 6 months of 1997.
a) This memorandum was the first time that the employer attempted to explain to any members of the P & E workforce, who exercised their right to be members of the CFMEU, the `why and how the PERs will be carried out' and it attached a copy of the PER document that will be used to record the discussion. This will give you an idea what is involved in the process ...'.
b) Furthermore, in Overburden, the production employees then had to wait until the end of September 1997 to the end of October 1997 to receive the employer's completed PER1 document, ie there was only about two months of the PER2 period left.
c) Moreover, it is apparent from reading the memorandum it provided no real meaningful assistance in explaining the PER system to a P & E workforce who had no training or familiarity in connection with PAs. Mr Finger said after receiving the memorandum that `I wasn't quite sure on all of their details they were going to go through': XX346 L20. Thus, there was no advance notice of the PER criteria and dot points given by the employer to P & E employees.
d) In this regard, Ms Arnold was asked
And Mr Prebble sent that out on 5 August 1997 which is after 30 June 1997, the end of the review period?---Accept - yes.
So that memorandum is not going to help anyone understand the system, being the performance appraisal system during PER1, is it?---No: XX2702 L24.
21) Fourthly, only 9 of the 16 applicants worked in Overburden at BA and the other 7 applicants never received any such memorandum to give them `an idea what is involved in the process'. There was no memorandum or written explanation for the PER system given to people like Mr Walsh or Mr McGuiness: Mr Riordan XX1752 L2. In this regard, Ms Arnold was asked A good indication for whether the employer attempted to publish and distribute and explain the standards would be if the employer sent out a memo or an explanatory document to employees to explain a performance appraisal system; that's right?---Yes: XX2702 L12.
22) Fifthly, whilst the supervisors were given some training on how to provide feedback to employees and to conduct PER sessions, there was no training on PA feedback and participation offered for subordinates.
a) Mr Barnes ex CFMEU50 sup para 11 - there were individuals with poor communication skills. In cross examination, he confirmed people had trouble when they were in front of management one-on-one. They felt overawed and have trouble expressing or saying what they really want. An example was Mr Walsh: XX861 L3.
b) Folger 1998 at p 120 lists 7 suggestions for doing fair performance evaluations and of relevance in the present context is train subordinates to participate. It would be helpful if subordinates were given the skills they need to obtain justice for themselves. Research strongly suggests that assertiveness training can promote fair PA. Such training included stating one's position in a confident manner, practicing non-verbal behaviour, listening to the other point of view, checking for understanding, and so forth: p 131.
c) The employer double standard of giving the above type of training to employees at Supervisor level and above, but not to P & E employees, is unfair.(My emphasis).
23) Sixthly, Dr Macdonald's `Effective Workplace Program 1997 - Version June 1997' (part of ex PC22) does not include any PER form:
a) The later version tendered in re-examination did include a copy of the PER form: ex PC27.
b) The `GM TEAM MEETING STRICTYLY CONFIDENTIAL (Not for distribution)' minute dated 29 April 1997 at p 2 states concerning these courses `its not a forum for code of conduct, PERs ...': ex PC40.
c) Mr Appleton said `I attended the 3 day course in Emerald from September 8, 1997. I think it was called `Effective Workplace Program'. To my recollection nothing in the course touched on the PER system. I can recall Mr Bates saying clearly one night that nothing in the course would be used to rate or assess any employee': sup para 7.
d) Mr Mick Duncan confirmed his course also did not touch the PER system - That didn't help you in understanding the PER system, did it, in terms of the criteria and the standards?---I don't think it had anything to do with the PER system. It is submitted that the AIRC would accept the evidence of Messrs Appleton and Mick Duncan. (My emphasis).
24) Seventhly, the minutes of the toolbox and/or safety minutes confirm that the objectives and standards were not widely distributed and explained by the employer in this type of forum:
a) One meeting where PERs were discussed, according to the minutes, was 25 June 1997 for `Earthworks' and this did not involve any of the applicants at that date: XX1466.
b) The only other minutes for any PER discussion was 22 May 1998 in relation to PER timing for Pit Production `F' shift. Again this meeting did not involve any of the applicants.
c) In March 1998, Mr McCrea gave evidence before the Commission that the PER system was discussed at these types of meetings. But in March 1999 he said he had not seen any toolbox meeting minutes and would prefer other people to be asked. He had been told it was discussed by Messrs Prebble, Keag and Yeates: XX1361.
d) Minutes were kept virtually always from early 1997. If there was a discussion of the PERs it should be in the minutes: Mr Keag XX1462-3. When he got to BA he put out a memo to the effect that supervisors should make sure the minutes were accurate: XX1548 L20. Mr Keag accepted that the minutes would be the most accurate record of what was discussed at these meetings and as a preference he would rely upon the typed document over his recollection 2 years later. There was a standard format and the minutes were signed off by the manager: XX1464.
25) Eighthly, the employer did not publish and distribute employer documents such as `Examples of where employees have attained the rating 3 in their PER's' (General Attachment 33 in ex PC8), `Unacceptable Behaviour' (GA 33), or `Guidelines Production Employees End 1997' (GA 39), to all P & E employees.
a) See for example: Mr Mannion X29, Mr Finger X345 L7 and Mr Gardner XX25437-2548.
b) Mr Yeates:
i) The `1997 Guidelines' were developed over Christmas 1997 and only became available to Supervisors after the second PER review period in early 1998: XX4305 L5.
ii) The `1997 Guidelines' would have been a good guide to provide to employees to try to educate them on company expectations and the company failed to issue that good guide to P & E employees: L11.
iii) The witness had a responsibility if he wanted to educate people about the system to provide this good guide: L27.
c) Ms Arnold was asked But that sort of information could assist in trying to explain the system if it was provided to the production and engineering employees who were to be assessed?---Yes, it might help them to understand what it was that was expected of them: XX2701 L17.
26) Ninthly, the employer failed to inform the applicants that they could get an automatic 1 for one of the four criteria until they read the employer statements in these proceedings: see, for example, the unchallenged evidence of Mr Mannion X29-30, Mr Halverson X157 L12, Mr Appleton X321 21, Mr Finger X344 L23.
27) Tenthly, there was no overall ranking lists or lists of the comments made available to P & E employees and:
a) These have only been obtained under a number of summonses to produce returnable before the Commission.
b) The employer refused the requests of Mr Barker to provide a copy of all PERs for production employees or a list with all names included for the retrenchment process so that his members could conduct a proper comparison of their performance against other employees. Mr McCrea only produced a document with the names of the applicants: para 3 in ex CFMEU48, para 2 in sup, X749 and Mr Keag XX1562 L12.
c) Mr Riordan as long ago as 12 Nay 1997 recorded for `Sing off the same hymn sheet (Organisation Restructure)' and there was to be `No Numbers/Charts': ex CFMEU84 at p 20.
28) Mr Keag summed up the position:
a) He has no way of knowing what explanation was given to each applicant: XX1526.
b) He was unaware of what each individual applicant would have seen.
c) A lot of the people in the workforce, including supervisors, are not Rhodes Scholars in terms of putting things in writing. They express things better verbally: XX1551 L13.
29) Ms Arnold initially claimed the due process requirement of `objectives and standards are established in advance, published, widely distributed and explained' could be satisfied by interleaving systems of an organisation such a safety system and training systems. See also RX2860, 3321-3322, 3331, 3384 as to her hypothetical propositions and speculation that there can be at workplaces other systems to establish in advance, publish and explain the objectives and standards for a PA. However, under cross examination she admitted she did not review such systems at BA and therefore she was unable to say how effective or otherwise these so-called systems were factually at BA: XX2698 - 2699. This exchange also took place:
Some of the managers and supervisors have admitted other systems didn't explain the performance appraisal system, so even - it means your qualifier is not satisfied if that's right?---Yes.
And it means the system is just fundamentally flawed for lack of adequate notice in the way described in the first point, 142, namely objectives and standards are established in advance, published, widely distributed and explained; that must be right?---Yes XX2702 L4 (emphasis added).
In re-examination she also said as part of an answer that `...The communication of an employee's meeting of the standards and the requirements of their job is helpful to enable them to go about their work more effectively...': RX3338 L15".
[88] The submission then turns to the fairness of the PER system as follows:
"b) Imperative of a P & E employee properly understanding the PER system &/or the so-called selection for retrenchment process
30) A necessary prerequisite for the fair operation of the employer's systems was for the employer to effectively explain the system and their intended purposes at the outset because:
a) The PER process was used for employer purposes as follows:
i) Maintaining applicants on the employer's `black list still to go'.:
ii) Offers were made for voluntaries by:
(1) `Giving ranking lists in terms of PER results, so performance results from top to bottom of crews': Mr Keag RX1622 L4.
(2) At the time of PER2 the bottom 100 or surplus employees were identified primarily through the PER system: Mr Keag RX1007 - 1008.
iii) There was a subjective selection of employees of those employees earmarked for retrenchment (at the time of PER2) based upon the sum of the answers in those four boxes, safety, personal effects, skills and teamwork which have a number of dot points under them: Mr McCrea XX1030 - 1035.
iv) Part of the process of who was to go with the PERs - this was the employer's thinking at 19 August 1997: Mr Riordan XX1755-6. So the PER was set up, in your contemplation, to identify those who were selected for a redundancy? Only part of it: XX1756 L3. This aspect of Mr Riordan's evidence is corroborated as follows:
(1) `Joe's Book 26/3/97' at p60 states `PERS - When deselection happens both PERs & Records of Discussion (Sick Leave etc) will be reviewed'. This entry appears to be late July 1997 in ex CFMEU84.
(2) The same note book at p74 states as part of the `GM Team Meeting 19/8/97'that `Criteria/Process for identifying those who will go - > PERs/Sick Leave/R of D/ Flexibility accepts'.
(3) Mr Crooks also confirmed he understood the first PER was to be used by the employer to offer redundancies: XX1849 L22.
(4) Mr Yeates also admitted that some of the applicants were selected for retrenchment where part of the justification was that they had not agreed to participate in PERs: XX4355 L10. The unfairness is manifest when the employer publicly told the same applicants tht it was a voluntary process.
(5) It should be noted Mr Bates in his assertion that the PER system was something that was not put in to work out who was to be retrenched (XX4450) is nothing other than an inaccurate attempt to recast history. (My emphasis).
v) Ms Arnold confirmed in respect of the answer by Mr Riordan in iii) above:
MR DOCKING: And, Commissioner, that was cross-examination, 1756 line 3. Now, assume it was in the contemplation of the employer that it was to be used to select people for redundancy. That would be a premium has to be placed on giving procedural fairness or due notice to employees?---Yes.
That's undeniable that you'd have to afford full due process in those circumstances, isn't it?---Yes.
Because it's the ultimate sanction if you're going to lose your job?---Yes: XX2703 L29 (emphasis added)
b) The PER process was also used as an important part of the so-called selection for retrenchment process:
i) The date from the PERs was used for ranking lists and also in the selection for retrenchment process: Mr Keag RX1630 L3.
ii) The ranking at the end of the day was the be all and end all of whether you stayed or not: Mr Riordan XX1704 L16. (My emphasis).
iii) See the fuller summary of the evidence in the Introduction.
31) Mr McCrea:
But an essential part of a proper performance effectiveness review system of the type you put at Blair Athol is that it be a two-way communication, isn't it -- Yes.
And two-way communication must, of necessity, mean that the worker being assessed understands the system, to give his or her feedback to the supervisor?---Yes: XX1289 L18.
Ms Arnold accepted that for these propositions they were respectively uncontroversial and not disputed: XX2701 L1.
32) In the Outline of Submissions by Pacific Coal Pty Ltd dated 3 February 1999 (ex PC21) the employer submitted that the Respondent had informed the employees of the importance of the PER process and that it would be one of the factors taken into account in selecting for any future redundancy.
33) Unfortunately, for the employer it never disclosed these matters to the P & E employees during the PER1 process:
a) Mr Barnes:
i) He did not know about the PER put together by Mr McCrea a real long time before the PERs actually started: XX791 L13.
ii) He did not know it had anything to do with retrenchments: XX801L24.
Ms Arnold had to admit in the face of this evidence - Well, if the Commission accepts Mr Barnes' evidence, and he gave some evidence on behalf of a lot of the applicants as he was a lodge official, if his evidence is accurate, the employer must have, in the circumstances the PERs were to be used to select people for redundancy, failed to give them procedural evidence?---If his evidence is accurate, yes then I'd agree with that: XX2704 L24 (emphasis added). See also RX3335 where the employer witness was incapable of explaining away this concession when given the opportunity.
b) Mr Mannion and Mr Halverson
i) The first PER was all done behind people's backs and they did not know it was going on: XX50 L19.
ii) The employer never turned around and sat down and told him what a PER was: XX51 L20. There was a probably a five minute conversation with the supervisor for each of PER2 and PER3: X30 L5. See also Mr Halverson as to he knew very little really about the PER process and the foreman hardly mentioned it: XX147 L21. Mr Halverson became aware of the idea of the PER process in about late 1997 as a result of general discussions that had taken place with other employees of BA: ex CFMEU9 para 7".
[89] The above summary of the applicants' submissions and extracts of evidence and cross-examination is, in my view, representative of the issues but do not, understandably, cover every issue and point raised.
The Year 2000 submissions of Pacific Coal
[90] I reiterate that I have considered all of the evidence and submissions presented and produced by Pacific Coal. I do not however intend to specifically refer to all of such evidence and submissions in detail in this decision other than to comment and/or summarise, and/or reproduce elements of the evidence and/or submissions I consider pertinent and which have assisted me in reaching my decision.
[91] The introduction to the submissions and the section defined as "2 Overview and Summary" of Pacific Coal as indicated earlier are reproduced hereunder as they directly confront what the CFMEU said about a number of the aspects which I have either summarised and or reproduced above, arising from the submissions made on behalf of the applicants:
". . . . . These proceedings involve claims by 16 former employees at the Blair Athol Coal Mine that they were unfairly dismissed. In their submissions the CFMEU for the Applicants have portrayed the Company's restructuring and redundancy programme as a deception to disguise a far more sinister plan to sack union activists and other undesirable employees. They have adopted an emotional approach reminiscent of the type of paranoia involved in looking for communists under the bed. Their submissions are littered with conspiracy theories attributing the worst motives to everyday events, and by this approach they have attempted to take the focus of these proceedings away from the real issues which are relevant to the determination of these applications".
[92] It was then submitted by Pacific Coal that the following summary puts these proceedings in proper context:
"During 1997 Blair Athol Coal undertook a fundamental review of its operations aimed at reducing operating costs and increasing productivity. The organisational review determined that the Mine was overmanned and accordingly it was planned to reduce total employee numbers by approximately 80 to 100. Details of this plan were communicated to employees and the unions on 13 November 1997. As part of this announcement the Company advised that it would be offering voluntary redundancy packages to employees identified as having no role after the reorganisation. Again the Company emphasised the importance of employee performance in determining who would remain following the restructure.
This emphasis on employee performance was nothing new. During 1996 the Company commenced the process of communicating to employees the importance of their performance and emphasising the need for employees to contribute to their full potential while at work. Employees were told that future retrenchment would be on merit and not by seniority.'
As part of the Company's productivity improvement plan it introduced a Personal Effectiveness Review (`PER') for all employees designed to identify areas of improvement. The PER was designed to be a simple system covering four areas which would be readily understood by the workforce, namely safety, teamwork, skills and personal effort. Employees were encouraged to actively participate in the review process.
The Unions at Blair Athol did not embrace the PER process, with the CFMEU at first discouraging employees to attend the PER interviews, and then moving to a position where it was left up to their members to decide whether they wished to participate. At the same time the CFMEU advised its members that it believed seniority would remain an award obligation and accordingly advised employees that the Company could not reduce workforce numbers based on performance measures.
It cannot be suggested that any of the Applicants were not aware of the importance of their performance if they wished to retain a role at Blair Athol. This was a constant theme during 1997 and 1998 as the Company moved to improve productivity and restructure for efficiency.
Management involved in performance assessment were trained and assisted in carrying out this role. As part of this focus on performance, managers of the Company were asked to each list the people they believed were the 50 worst performers at the Mine. This was a training exercise to promote discussion about criteria to use in assessing performance. Many of the employees who were first thought to be in the worst 50 employees are still employed, even though more than 50 have been terminated. This is because employees improved their performance and because final retrenchment decisions were made on set criteria and not in the same manner as that initial exercise. This list was not in any way used for retrenchment decisions made 18 months later.
Later in 1997 a rating list was produced for the purpose of identifying employees who would be offered voluntary redundancy. The PER process had been used as input into this rating list, however it was also necessary to factor in the changes in performance that had occurred since the previous assessment. Because numbers needed to be reduced by about a third, colour coding was introduced to differentiate between groups of employees using the colours of blue, red and black, and in maintenance, brown. The development of rating lists in this colour format was to assist planning for the restructure is explained by Rod Bates and Darren Yeates. It is outrageous to suggest that the colour coding was anything other than a convenient aid to decision making. The only input into this rating list was performance and there was no relationship to other factors such as whether people were on AWA's or not or whether employees were union delegates, union activists or union members.
Much has been made by the Applicants in their submissions about `black lists' and `black lists still go'. Yet the evidence about the development of this coloured rating list was not successfully challenged in cross examination. The Applicants have done everything they can to sensationalise and beat up the issue of `black lists still to go', however the fact is that they have failed to demonstrate that the rating list related to any factor other than performance.
produced under summons was not in colour. While this was unfortunate, it was an innocent mistake arising from the summons document being a copy sent by facsimile in circumstances where the recipients did not know that there were coloured originals. While the colouring obviously did not come out in the facsimile, the material provided was the same and gave full details of the ratings and the position of the Applicants.
The production of the organisational chart by the so called whistle blower witness, Ms Janene Hoch. This Exhibit included the reference to `black lists still to go' and was characterised by the Applicants as a revelation demonstrating that the Company had not complied with the summons and had hidden the existence of a so called black list. However organisational charts were never summonsed, the Exhibit is not a ranking list, and the evidence has demonstrated that the evolution of the terminology `black list' was not sinister.
The overwriting in Mr Riordan's notebooks of references to black lists. If anyone has been badly treated in these proceedings it is Mr Riordan. He selected the pages which included the overwriting and obliteration. It can hardly be suggested that he was trying to hide this material from the Commission or the Applicants. The changes in many cases were clear to the naked eye and the obliteration stood out like a neon sign. Yet the Applicants seized upon this as some sort of revelation and confirmation of their conspiracy paranoia and quite improperly and inappropriately raised the stakes by suggesting offences under the Commonwealth Crimes Act. In the circumstances it is quite understandable why Mr Riordan then sought independent legal advice and refused to answer further questions on this topic. The Applicants' treatment of Mr Riordan deprived the Commission of the ability for Mr Riordan to explain what was in his notes. It also unfairly deprived the Respondent of the ability to adduce further evidence from Mr Riordan to answer allegations made against it based on the notebooks.
But notwithstanding this beat up and sensationalism, the evidence is that the coloured lists were based on performance. There is simply no evidence to justify the assertion that some secret `black list' was created to target the Applicants and target union activists. On the contrary an employee's position on the list changed as their performance changed with the result that some employees on the `black list' are still employees at the Mine. This in itself demonstrates that the conspiracy theory of the Applicants is simply untrue".
[93] At this point in the submissions it is relevant to note that the Pacific Coal stamp is put on the PER system in such a way that the differences between what the CFMEU's submissions allege about the applicant's treatment under the application of the PER system are put in stark relief:
". . . . . The PER system will be dealt with in greater detail later in these submissions. Generally, however, it is a simple system which requires an employee's supervisor to make an assessment of each employee's performance in 4 key areas; safety, team work, skills and personal effort. The assessment is made by assigning a rating of 1, 2 or 3 for each of these areas. 1 is a rating which indicates that the employee is not meeting expectations, 2 indicates that the employee meets expectations and 3 indicates that the employee is exceeding expectations. The supervisor bases the assessment on his observations of the employee's performance during the assessment period. The assessments are made each 6 months. The assessment form contains a number of guidelines, in the form of bullet points, to guide the supervisor in considering each of the 4 criteria.
Preparation forms were also provided to supervisors to assist in focussing their attention on each of the 4 criteria, to enhance the quality of their assessments. The supervisors were also provided with detailed training to permit them to carry out the assessments. Each supervisor's assessments were then subject to a review process to ensure consistency. When this had occurred, and the assessments were finalised, feedback interviews were held with employees. This was a key part of the system as it was a means by which an employee and his supervisor would discuss the employee's performance, and the way it might improve. This was the real benefit of the system. It is important to note that the feedback session was not a `negotiation' nor a means by which the supervisor's assessment could be changed.
There was also the capacity for an employee to appeal the assessment of their supervisor, with respect to one or more of the 4 categories. This appeal was heard by the relevant manager and the employee was permitted to make representations to the manager in dealing with the appeal.
The PER system for production and engineering employees was introduced in mid-1997 with the first assessment being conducted in June 1997 and subsequent assessments taking place each 6 months since that time. Additionally the employees were given detailed information about the PER system through the `effective work place programme' which was presented to most employees. It described why the company implemented the PER system, defined the work of a team and team leaders and explained team processes.
Other changes flowing from the strategic review included the adoption of single face mining, a more efficient method than the 2 face mining which had previously been used; the expansion and improvement of the Tritonics system, the adoption of uniform standard operating procedures and improvements to shot firing.
A feature of the introduction of these and the many other changes which were at that time made to enhance the productivity and efficiency of the operation was the open consultative environment in which the changes were developed and implemented. In addition to the effective workplace programme, employees were regularly briefed by the General Manager at `State of the Nation' addresses and were invited to take part in the strategic review itself. It was the involvement of the company's employees (both award employees and staff) which lead to the `over 100 suggestions' for reducing costs and improving productivity. Additionally, the General Manager regularly communicated with employees directly by way of written memorandums, posted on notice boards and sent to employees' residences.
The strategic review team developed an organisational chart which indicated that the mine could continue to produce the same amount of coal with 200 employees, a reduction of more than 100 employees. This downsizing was achieved through a system of targeted voluntary redundancies of poor performing employees. Employees who were eligible for voluntary redundancies and who chose to take them were paid severance benefits above and beyond their legal entitlements. It was not necessary for the company to terminate the employment of any employee to achieve this downsizing. As these redundancies took effect, and the benefits of many of the changes began to take effect, it became apparent that the mine could be operated to produce the required number of tonnes per year with fewer than 200 employees. It was calculated that the appropriate number was about 180.
After voluntary redundancies were exhausted, it was necessary for the company to compulsorily retrench some 16 employees. These terminations are the single change flowing from the restructure the Commission is concerned about in these proceedings. The company set out about devising a method by which it would select which 16 employees to make redundant. The method that the company chose to make this selection is at the heart of what the Commission must decide in this case. There is no evidence upon which the Commission can find that the decision to downsize was not open to the company; clearly the company was entitled to decide to restructure its operations, to achieve greater efficiencies. Nor can the Commission make any adverse findings about the voluntary redundancies.
The sole matter to be determined in the proceedings is whether, in terminating the employment of the 16 applicants, the company acted harshly, unjustly or unreasonably.
2.4 Selection process
The process used to choose the current 16 Applicants for retrenchment is set out in general attachment 17 of Exhibit PC8. It can conveniently be summarised as involving the following 3 steps:
Arriving at an assessment of an employee's past performance with the company in the 4 areas of safety, skills, teamwork and personal effort. Each employee received a ranking from 1 to 5 for these areas. This assessment was a separate independent assessment of past performance. Whilst it utilised data from the previous 3 PER's, it was a completely different assessment and the PER material was only one input. This was not only because of the different range of scores (1 - 5) but also because the assessment was not restricted to a particular time period. The 3 PER's related to an 18 month period of employment. The average length of service of the Applicants with the respondent was in the order of 10 years.
Employees were then assessed on their ability to meet future role requirements at Blair Athol. The company determined that the critical areas for the future of the mine were:
· willingness and ability to adapt to change, new technology and new processes;
· communication and relationship building skills;
· team leadership and membership qualities including being prepared to make decisions,
· use discretion, take responsibilities for action; and
· contribution to the business through improving work processes, wastage and costs.
It was of course imperative to ensure that the company selected employees to retain who had the appropriate number of skills and licences across the site to maintain production and maintenance requirements. When the retrenchment selection procedure was applied, the current 16 Applicants were selected for retrenchment. Each had the opportunity to appeal against that selection to the General Manager . . . . . .".
[94] The structure of the Pacific Coal closing submissions were presented in two parts defined with the first part, as the Main Closing Submissions containing the relevant legal principles and evidentiary matters which relate to the applicants generally.
[95] Following the Main Closing Submissions, the submissions were then individualised for each individual applicant. These submissions were described as setting out the evidentiary basis for the Pacific Coal submissions in relation to the particular applicant based on the legal principles set out in the Main Closing Submissions and included in part, but are not limited, to the following:
"7 Procedural Fairness - A Fair Go All Round
7.1 Obligation to Observe Procedural Fairness
The obligation not to treat an employee harshly, unjustly or unreasonably even in the case of a genuine redundancy has long been established. See the comments of Beazley J in Quality Bakers at 334:
`Even in the case of a genuine redundancy, the termination of employment of a particular employee may be harsh, unjust or unreasonable: Needham v Shepparton Preserving Company Limited (1991) AILR 395; Cheesman v Kinhill Engineers Pty Ltd (1992) 59 SAIR 168; Corkery v General Motors Holden Limited (1986) AILR 429; Hemmings v CPS Credit Union (1991) 58 SAIR 421.'
See also the comments of Justice Ryan in the Jones v Department of Energy and Minerals (1995) 60 IR 304 at 309.
7.2 What is `Procedural Fairness'?
What constitutes procedural fairness in each case will vary according to the circumstances. In Gregory v Philip Morris (1988) 80 ALR 455 Jenkinson J said at 457:
`The question whether the termination was unreasonable is, I think, one of fact. This question requires a determination, by reference to moral values and prudential considerations current in the community, of what the tribunal of fact thinks a reasonable employer in the circumstances would have decided to do at the time when the respondent terminated the appellant's employment. The process is similar to that by which the questions whether a personal injury or damage to a chattel has been caused by a person's negligence are resolved: what does the tribunal of fact think that a reasonable person placed in the circumstances in which that person was placed would have done?'.
According to Sheppard and Heery JJ in Bostik v Gorgevski (No.1) (1992) 41 IR 452:
`... the Court must decide whether the decision of the employer to dismiss was, viewed objectively, harsh, unjust or unreasonable. Relevant to this are the circumstances which led to the decision to dismiss and also the effect of that decision on the employer. Any harsh effect on the individual employee is clearly relevant but, of course, not conclusive.'
7.3 Relevance of Findings with Respect to Procedural Fairness
Contrary to the submissions of the CFMEU the weight of authority is in favour of the view that a finding of an unfair procedure does not automatically make a termination harsh, unjust or unreasonable: CFMEU Closing Submissions Part 10.
In Byrne and Frew v Australian Airlines (1995) 131 ALR 422, Brennan CJ, Dawson and Toohey JJ at 434 the majority of the High Court accepted the respondent's contention that:
`Whilst the adoption of an unfair procedure may render the dismissal harsh, unjust or unreasonable whether it does so or not must depend on the whole of the circumstances.'
See also Ritter J in Powers v ANI Corporation Ltd (Unreported: IRCrt, Ritter J, 22 August 1996) who after a detailed analysis of the relevant authorities including the Bryne and Frew Case commented at 13 that :
`To the extent that it is sensible to consider the procedural and substantive issues relating to a termination of employment separately, procedural defects may, but not must, lead to a finding that the termination of employment is harsh, unjust or unreasonable ...'
The CFMEU submit that the test for procedural fairness is that set out in the academic works to which they refer and in a decision of the NSW Commission: CFMEU Closing Submissions Tab 2 paras. 1 - 12. The Respondent submits that the appropriate test for procedural fairness is as set out in the authorities cited above. These authorities carry greater weight and are of more relevance than the opinions of academic authors and State tribunals considering the application of different legislation.
7.4 Evidence of Procedural Fairness
The Respondent submits that the treatment of each of the Applicants was procedurally fair and their selection for retrenchment termination was not harsh, unjust or unreasonable in the circumstances. Evidence of the Respondent's fulfilment of it's obligations in determining that the Applicants be made redundant are set out below. This evidence shows that the Respondent did observe procedural fairness in the case of each Applicant.
To the extent that there can be said that there was any minor defect in the procedure (the Respondent submits that any defect which occurred is only minor in nature), the Respondent submits that on the authorities cited above such defect does not make the Applicant's selection for retrenchment necessarily harsh, unjust or unreasonable in the circumstances. (My emphasis)
In these submissions the Respondent has included detailed material concerning procedural fairness, particularly in material dealing with an opportunity to answer allegations in Part 14 of the Respondent's Closing Submissions. That, of course, is a matter which the Commission is statutorily required to consider pursuant to section 170CG(3)(c).
Suffice it to say, the gravamen of the Respondent's contention regarding the procedural fairness which was afforded to the Applicants was the appeal process by which the Applicants were afforded an opportunity to appeal directly to the General Manager Mr Bates, the very person who made the decision to terminate their employment, about that decision. Circumstances surrounding that appeal are compelling evidence of the procedural fairness which was afforded to the Applicants. They include the frank and forthright nature in which the company informed all employees of the procedure which would be adopted to select those employees who employment was to be terminated, the fact that the Applicants were provided with correspondence informing them that a provisional decision had been made to terminate their employment, the basis of that decision in terms of their scores on the criteria were set out and the Applicants were provided with documentary assistance to prepare an appeal. The Applicants were represented by a full time and experienced union official at the hearing of the appeals. Mr Bates had distanced himself from the procedure which led to the provisional selection of the Applicants to ensure his objectivity and independence so far as hearing the appeals was concerned.
. . . . .
Further, the Respondent put in place a system available to the Applicants to provide them with the opportunity to obtain substantial feedback concerning their performance in the 18 months prior to the decision to retrench. The significance of the Applicants voluntary decision to effectively `ignore' their own supervisor's assessments of their performance, and suggestions for ways that their performance could improve, is also dealt with at some length later in these submissions. The significance of the Applicants failure to appeal to MRU manager concerning the contents of their personal effectiveness reviews is also dealt with in these submissions. Put shortly, the Applicants cannot now be heard to allege that they `never did anything wrong' and that the matters raised in the PERs are untrue, when they chose not to challenge those assessments and comments at the relevant time.
The credit of the Applicants suffers substantially when one considers the circumstances surrounding these PERs. Their decision not to challenge (in the overwhelming majority of circumstances) their supervisor's assessments of their performance until years after those assessments were made, speaks volumes about their recent denials that they `never did anything wrong'. That is, it is unfair for the applicants to say nothing about the accuracy of the matters recorded in their PER's until these proceedings commenced and then, through their legal representative, they take supervisors to task about these matters some years after the events concerned. Clearly they should have taken the opportunity to challenge at the time. It is unfair to the supervisors and the Respondent to delay this challenge when a process was available at the time.
Where it was used by the Applications the evidence is that PER scores were changed. In any event the PER system itself is not on trial here, for it was the system designed to promote improved performance. The Commission must focus on the appeal process to the General Manager, Mr Bates.
. . . . .
8. 170CG(3)(a) - Valid Reason
8.1. Introduction
Section 170CG(3)(a) provides that in considering whether the termination of the applicants employment was harsh, unjust or unreasonable, the Commission must have regard to:
`(a) whether there was a valid reason for the termination related to the capacity or conduct of the employee or to the operational requirements of the employers undertaking, establishment or service;'
8.2. Meaning of Valid Reason
A reason is valid if it is sound, defensible or well founded. That test is to be applied in a practical common-sense way to ensure that employer and employee have both been treated fairly: see Selvachandran v Peteron Plastics Pty Ltd (1995) 62 IR 371 at 373 per Northrop J; Kerr v Jaroma Pty Ltd (Unreported: IRCA, VI 3306/95); Andrews v Ian Rollo Currie Nursing Home (Print PO321, Whelan C, 21 April 1997) at 8-9.
8.3. Significance of Valid Reason
The employment of employee may be validly terminated for a reasons or reasons related to the operational requirements of the employers business and/or for a reason related to the employee's capacity or conduct, or for reasons of both kinds.
A finding that the requirement of a valid reason has not been met is no longer determinative of whether a termination is harsh, unjust or unreasonable: Windsor Smith v Liu and Others (Print Q3462, Full Bench: Giudice J, Polites SDP, Gay C, 13 July 1998) at 10:
`Whether there was a valid reason for the termination is only one of four separately specified matters which the Commission must now have regard to. The Commission must also have regard to any other matter it considers relevant. There is no causal connection between a finding that there was no valid reason for the termination and a conclusion that the termination was harsh, unjust or unreasonable. In summary, the question of whether there was a valid reason for termination of employment is no longer the critical question in determining whether the termination was contrary to the Act. Under the IR Act provisions if no valid reason existed then the applicant was prima facie entitled to reinstatement or compensation.'.
While the existence of valid reason is not, of itself, determinate of the question whether the termination is harsh, unjust or unreasonable, the Respondent acknowledges that `it will often be a very important factor': Windsor Smith v Liu and Others (Print Q3462, Full Bench: Giudice J, Polites SDP, Gay C at 10).
According to Northrop J in Selvachandran v Peteron Plastics (1995) 62 IR 371 at 374:
`...normally the issue of whether a reason for termination is valid or not should be considered primarily from the employer's perspective...'.
It is a question of fact as to which category the reason for the termination of the Applicants employment in this case falls. Based on the evidence, the Respondent submits that the terminations occurred for a valid reason which was related to the Respondents' operational requirements. In the alternative, the valid reason for the terminations related to both the respondents operational requirements and the applicants capacity or conduct.
8.4. Valid Reason - Operational Requirements
The term operational requirements has been given a broad interpretation by the Courts. In Nettlefold v Kym Smoker Pty Ltd (1996) 69 IR 370 Lee J held at 373 that the phrase `operational requirements' is:
`... a broad term that permits consideration of many matters including past and present performance of the undertaking, the state of the market in which it operates, steps that may be taken to improve the efficiency of the undertaking by installing new processes, equipment or skills, or by arranging for labour to be used more productively, and the application of good management to the undertaking'
This approach has been affirmed in Shorten v Australian Meat Holdings Pty Ltd (1996) 70 IR 360 and has been held to be expressly applicable to section 170CG(3)(a): Fetz v Qantas Airways Limited (Print P6706, per Ross VP, 17 November 1997); Liu v Coms 21 Limited (Print R9249, per Lawson C, 27 September 1999)
In Mitchell-Collins v The La Trobe Council (1995) 60 IR 480 Justice Spender acknowledged that a redundancy situation fell clearly within the scope of `operational requirements'. At 488 he said:
`It is clear that `operational requirements' of a business may include redundancy. A redundancy will arise where a job - as distinct from a particular employee - is no longer required. This could occur where an employer has labour in excess of the requirements of the business; where the employer no longer requires to have a particular job performed; or where the employer wants to amalgamate jobs: R v Industrial Commission of South Australia; Ex parte Adelaide Milk Supply Co-Operative Limited (1977) 44 SAIR 1202 per Bray CJ, 1205; Gromark Packaging v FMWU (1992) 46 IR 98, per Franklyn J at 105.'
The Adelaide Milk Supply case was also referred to by Justice Ryan in Jones v Department of Energy and Minerals (1995) 60 IR 304 at 308 who confirmed the company's right to rearrange its business:
`However, it is within the employer's prerogative to rearrange the organisational structure by breaking up the collection of functions, duties and responsibilities attached to a single position and distributing them among the holders of other positions, including newly created positions. ... What is critical for the purpose of identifying a redundancy is whether the holder of the former position has, after the reorganisation, any duties left to discharge. If there is no longer any function or duty to be performed by that person, his or her position becomes redundant in the sense in which the word was used in the Adelaide Milk Co-Operative case.'
Where the reason for a termination is related to the employers operational requirements, the employer does not have to prove that its approach is justified upon economic or financial grounds: Quality Bakers of Australia Ltd v Goulding and Another (1995) 60 IR 327. Thus:
`An employer might decide to make certain positions redundant with the sole intention of increasing the profitability of an already profitable business. Such a decision would relate as much to the operational requirements of the business as would a decision as to redundancies taken in the case of a business which was in a parlous financial condition or when a certain type of work was no longer undertaken by the business' (at 333).
See also Mitchell-Collins v La Trobe Council (1995) 60 IR 480 at 489 (per Spender J) and Orchard v External Constructions (Print P3902, Watson SDP, 8 August 1997)..
. . . . .
The Respondent submits that the evidence set out below demonstrates that the Respondent had genuine operational reasons for undertaking the restructure which ultimately resulted in the terminations of the Applicants. Accordingly the reasons for the termination of the Applicants were valid and had the required connection with the operational requirements of the Respondent's business......
. . . . .
8.7. Selection Criteria
The approach adopted by the Respondent was to adopt selection criteria which would lead to the retention of the best employees for the available positions in the new structure.
The criteria to be used for selection for retrenchment was set out in a memo to all staff on 12 June 1998: Exhibit PC 8, Attachment 17 referred to in Exhibit PC 22 Witness Statement of Mr. McCrea at para 79; Exhibit PC 74 First Witness Statement of Mr Bates at para 96 and Exhibit PC 72 First Witness Statement Mr Yeates at para 97.
The selection criteria were as follows:
`Overall Employee Performance - This will include all previous performance and the results of Performance Reviews including the one completed this month for the first half of 1998.
As with previous Performance Reviews, employees will be assessed on:
· Safety
· Skills
· Personal Effort
· Teamwork
Future Requirements for Employees - We need to retain employees who we judge as being willing and able to meet the future role requirements at Blair Athol. To assess this each employee will be scored on these criteria:
· Willingness and ability to adapt to change, new technology and new process.
· Communication and relationship building skills.
· Team leadership and membership qualities including being prepared to make decisions, use discretion, take responsibility for actions.
· Contribution to the business through improving work processes, wastage and costs.'
The reason for the adoption of the selection criteria was to ensure that the Respondent retained its best 200 employees bearing in mind the future requirements of the mine: Exhibit PC 74 Witness Statement of Mr Bates para 90-93; Exhibit PC 22 Witness Statement of Mr McCrea at para 89; Exhibit PC 28 Witness Statement of Mr Keag at para 88-89.
The use of performance related criteria was clearly explained to employees at the mine prior to June 1998. For example we draw the Commission's attention to Exhibit PC 8 General Attachment 8. This is a memo from Mr Bates to Managers, Superintendents, Supervisors and Team Leaders dated 13 November 1997. The memo requests that these people `please communicate' its contents to the employees and their workgroups. Page 2 of the memo sets out the criteria for retrenchment which, at that time, the company was considering. This included `skills or ability to gain required skills' and `employee performance in current or previous roles' including:
· attendance
· teamwork
· safety
· personal Effort
· proficiency
While the final criteria were more refined than these this document is evidence of the company's frank and open communication with employees concerning the way in which the company would determine who would remain after the restructuring".
[96] The following passage is, in my view, very important as the CFMEU alleged that the treatment of the applicants was unfair in that their selection was based upon an abuse of the criteria chosen by Pacific Coal in the application of the PER rankings to the extent that there was inconsistency in the application of the criteria.
"8.8. Validity of Selection Criteria
8.8.1. Choice of Criteria is a Matter for the Employer
The adoption of the selection criteria to select employees for redundancy from a pool of eligible employees is a matter within the discretion of the employer subject to it being fair: see Full Court of Industrial Relations Court of Australia Kenefick v Australian Submarine Corporation (No 2) (1996) 65 IR 366 at 372; per Farrell JR Craig v West Australian Petroleum Limited (1997) 76 FCR 419. Provided that the employer's method of selection is based on fair and reasonable criteria the court should not interfere with its decision even though other reasonable approaches could have been adopted which would have preserved the applicant's employment: per Patch JR Pritchard v Standard Chartered Bank of Australia (1996) 64 IR 315 at 318.(my emphasis)
8.8.2. Use of Performance Based Selection Criteria
In numerous decisions the Commission and relevant Courts have acknowledged that an employer is entitled to retain better performers in favour of poorer performers. See for example Wilcox CJ in Kenefick v Australian Submarine Corporation (No 1)(1995) 62 IR 107 at 117:
`The achievement of maximum productivity being a matter of critical importance to ASC, the company cannot fairly be criticised for selecting criteria designed to maximise the productivity of its retained employees rather than a formula, such as `last-on, first-off', that might cost it some of its best employees.'
We note that this aspect of the decision commenting on selection criteria was not overturned by the Full Court on appeal. See also Miller v Northwest Meat Processing (Print Q2343, Raffaelli C, 25 June 1998) at 5:
`I consider that in reducing its workforce, the desire to reduce the number of slicers and to keep those whose performance was superior was a reasonable management decision.'
8.8.3. Justification for the Use of Performance Based Criteria
A decision as to whether the employer's method of selection is based on fair and reasonable criteria is one the Commission should make after due consideration of those criteria in the context of the business needs of the Respondent: see for example Brooks v Australian Dried Fruit Sales Pty Ltd t/as Sunbeam Foods (1998) 84 IR 33 (per Simmons C). In that case, selection criteria were found to be unreasonable and unfair due to the short period for assessment of two weeks, the fact that the criteria were prepared for the purposes of identifying training needs and not retrenchment and the skewing of the weighting in favour of matters not directly related to the Respondent's business over those that were directly related.
The Respondent submits that the weight of evidence strongly supports the conclusion that the criteria chosen in this case are reasonable and defensible in the context of the present and future requirements of the Respondent's business:
· Ample evidence has been led by the Respondent that its business was to be thoroughly reorganised to prioritise flexibility, personal effort, team work, initiative and other matters going beyond the narrow core competency of an employee: Exhibit PC 22 First Witness Statement of Mr McCrea at para 79-92; Exhibit PC 74 First Witness Statement of Mr Bates at para 56-58; Exhibit PC 28 First Witness Statement Mr Keag at para 74-82.
· The selection criteria chosen were designed specifically for the purpose of selecting the best performing employees for retention (unlike the criteria, of which the Commission was critical, in Brooks v Australian Dried Fruit Sales Pty Ltd t/as Sunbeam Foods (1998) 84 IR 33 which was originally intended to identify training needs).
· Even though the selection criteria included factors going beyond the bare requirements of an employee's specific tasks (eg the narrow task of driving a dozer) to include matters such as ability to accept change, communication and leadership, these are not unreasonable criteria given the wholesale change to the Respondent's operations brought about by the restructuring process and the future requirements of the business for flexibility and increased productivity: Exhibit PC 74 Witness Statement of Mr Bates at para 56-58; Exhibit PC 28 Witness Statement Mr Keag at para 88.
· The authorities make it clear that it is for the employer to decide which criteria it will use: See further the Respondent's Closing Submissions Part 8.8.1. Unless the Applicants are able to show that these criteria are demonstrably unrelated to the nature of the Respondent's business, then the Commission, it is submitted, should be reluctant to interfere with the employer's choice of criteria".
Applicant's general submissions in reply
[97] The submissions in reply for the applicants raised questions about the defence of Pacific Coal to the allegations made and responded to in the Pacific Coal submissions by way of the following:
"EMPLOYER'S SYSTEMS CANNOT BE PUT TOGETHER AGAIN
1) Like Humpty Dumpty in the children's fairytale, the employer's selection processes have, in the course of these proceedings, fallen to the ground and the smashed pieces can not be put together again by the employer. The three PERs were undeniably an integral part of the employer's selection for retrenchment processes. They are properly characterised as substantial and operative reasons in the employer's purported justification for the selection of the applicants for termination. Part of the employer's selection processes was the placement of all fourteen (14) Production MRU applicants on the `black list still to go' and this was long before the G block meeting of the employer on 22 June 1998 where the `Past Performance' and `Future Requirements' scores were `massaged' (using the admitted expression of Mr Yeates).
2) Reinstatement is an appropriate remedy. In PKIU v Vista Paper Products Pty Ltd and others Print K1039 (13 December 1991) Riordan DP awarded reinstatement of 33 applicants as the interests of equity and justice required this conclusion. This decision of the AIRC survived all challenges. It cannot be said that there is any prospect that BA's open cut coal mine, with its best mining conditions in the world and viability, will close down and thereby frustrate the AIRC's decision.
3) In Essex Oaks Pty Ltd v Reed Print S3907 (6 March 2000) (Boulton J, Acton DP, Lewin C), after carefully considering the relevant provisions of the WR Act and in particular s 170CH(3), declined to grant leave to appeal from a decision of a single Commissioner awarding reinstatement of an employee on terms. The Full Bench said:
`[5] In reaching her decision on remedy, the Commissioner had regard to the special circumstances of the case before her. She said that `under the circumstances of this case it is appropriate to reinstate the applicant to the status of 'regular hire employee' on the basis that the employer should not be able to benefit from its prior unconscionable conduct. To do otherwise would not, in my view, be consistent with the objects of section 170CA.'
[6] In our view, it was reasonably open to the Commissioner to reach the conclusion on the evidence and material before he and it was permissible under the Act to make the order appointing the employee to the relevant position. The order made was therefore within jurisdiction and was reasonably open to the Commissioner as an exercise of discretion.' (emphasis added)
4) Thus, the applicants submit that, on the evidence and material before the AIRC in the present cases, it is appropriate to reinstate the applicants (n.b. Mr Bettridge who had previously sought compensation how seeks reinstatement). To do otherwise would not be consistent with the objects of s 170CA and the employer should not be able to benefit from its prior unconscionable conduct.
5) It is sixteen (16) natural persons who are the applicants in the present proceedings. Whilst in the face of the activities of the employer at BA they had principles and guts enough to adhere to their individual choice to belong to the CFMEU, the employer persistently in its submissions mistakenly refers to the applicants as the CFMEU. Regrettably, the employer's submissions are riddled with even more serious substantive factual inaccuracies and incorrect statements of principles.
ANOTHER EMPLOYER RECANT
6) The desperate attempts of the employer in its submissions to distance itself from the PERs speaks volumes of its own recognition that the applicants have decisively proved on the evidence before the AIRC that the applicants were never accorded a `fair go all round'.
7) Examples of its most recent contentions in February 2000 include:
a) `It is the retrenchment process and Exhibit PC74 which the Commission should focus its attention upon in deciding the matter. It is not the PER system, for that was not the system which was used to select employees for forced redundancy' (pp 6-7).
b) ` ... This case is not about the PER system. The fact that so many days of evidence were devoted to a close examination of the PER system was because the Applicants, it is submitted erroneously, decided to conduct their cases this way. Exhibit CFMEU74 was prepared having regard to 8 criteria. Only 4 of those criteria reflect the criteria in the PER system' (6.3 p 25). The two emphasised parts of the employer's recent contentions contradict each other and belie the tangled web within which the employer has caught itself as it struggles to come to grips with its inability to put the smashed pieces of its systems together again.
c) `In any event the PER system is not on trial here, for it was system designed to promote improved performance. The Commission must focus on the appeal process to the General Manager, Mr Bates' (1.4 pp 29-30).
d) `The process by which the Applicants were selected is outlined above. The PER system was an entirely separate process designed to improve performance. The 'verification' of the PER scores is therefore irrelevant' (8.12.4 pp 92-3).
e) ` ... the PER system is not relevant because it did not from the basis of the forced redundancy process, which was a separate and distinct process' (9.4.3)
f) `It is fair to say that in selecting the Applicants the PER's were relied upon to a greater or lesser extent by the various managers of the Respondent. However, this in and of itself does not make them the same process; the differences referred to about this make the conclusion inescapable.' (11 p 174) (emphasis added). Once again, the employer's year 2000 contentions are internally contradictory and belie the tangled web within which the employer has caught itself.
g) Under the heading `14 170CG(3)(c) - Opportunity to Respond' it was said `Evidence in relation to the PER system is clearly not relevant to whether the Respondent met this obligation' (14.1 p 196).
h) `It is not put by the Applicant that there is any connection whatever between the 4 future requirements and the PER system, nor could any such suggestion ever be made out.' (see, for example, Mr Kelly p 4).
i) `There is no direct connection between the PER system and the allocation of scores for the first 4 'Previous Performance' criteria ...' (see, for example, Mr Kelly p 4).
j) `A completely new selection process occurred for the forced retrenchments' (see, for example, Mr Kelly p 18.3).
8) The employer has done no less than recant its own `Outline of Submissions by Pacific Coal Pty Limited' dated 3 February 1999 (ex PC21) in the following areas:
. . . . . .
9) The AIRC in Smith and Others v Pacific Coal Pty Ltd Print S0195 relevantly said:
`Mr Longland made a concession as to the recall of Mr Riordan which Mr Allen, on 10 September 1999, now seeks to recant on the grounds that Mr Longland made such concession whilst not being aware of certain matters.
The exchanges referred to at pages 10-11 of this decision (Transcript page 2351) are quite specific and represented, in my view, an open invitation to Mr Docking to make application for the recall of Mr Riordan so as to avoid the Browne and Dunn objection scenario.
....
I will also require the recall of Mr Riordan for further cross-examination when these proceedings resume on 15 November 1999 as in my view the concession made by Mr Longland on 6 September 1999 was reasonable in all of the circumstances as instanced in the Applicants submissions and importantly was a concession the Applicants were entitled to rely on from the time it was given.' (emphasis added)
10) The AIRC should apply the same approach to the more recent employer attempt to recant on its submissions made 12 months earlier at the beginning of the case as these were concessions that the applicants have been entitled to rely upon from the time they were given. In other words, the case was conducted on the employer's own territory which undeniably included the PER process as a pivotal issue.
11) In Manuel v Pasminco Cockle Creek Smelter Pty Ltd (1998) 83 IR 135 the employer argued that the selection criteria did not include a consideration of `conduct or performance' of a kind that could be put as an allegation to each of the applicants. This was despite having previously provided particulars to the representatives to the representatives of the applicants. The Pasminco particulars have a glaring analogy with the present employer's `Outline of Submissions by Pacific Coal Pty Limited' dated 3 February 1999 (ex PC21). It was held by von Doussa J:
`In answer to a request for particulars of the Selection Criteria used, solicitors for Pasminco in a letter dated 11 November said:
`The factors and characteristics which the managers took into account in deciding who to select for the available positions were the individual skills possessed, skills applied, knowledge and expertise, experience, observed work traits and flexibility, and, in some instances and to some degree, observed overall performance'.
In my opinion this selection process necessarily involved, as a matter of fact, taking into account the past performance of each of the applicant that could be brought to the attention of the applicants, in the form of allegations, which they very probably would want to answer.'
12) von Doussa J also said that `capacity' is apt to describe a future capability and the past conduct or performance of the employees is necessarily considered as an indicator of likely future performance. It was a comparison made which involved, to an extent at least, past conduct and performance.
13) In the present cases, the same judicial logic confirms that the so-called `future capability' of an applicant when being assessed for the `Future Requirements' at BA meant the employer used past conduct and performance. This necessarily included past conduct and performance in the PERs as shown by the following:
a) The employer when trying to explain why an applicant like Mr Kelly received particular scores for `Future Requirements' in its submissions proceeded to refer to allegations of past conduct or performance and even comes the full circle where it said `Clearly the Applicant's previous conduct and his poor performance in relation to the criteria (Future Requirement of `Team Leadership and Membership') allowed the respondent to reach the fair and reasonable conclusion ...'.
b) The employer's admissions in respect of the use of the PERs for `Future Requirements' and/or the inconsistencies between the scores for these criteria and the employer's own internal documents is dealt with in more detail below.
14) Thus, the employer's submission that the applicants did `not put ... that there is any connection whatever between the 4 future requirements and the PER system, nor could any such suggestion ever be made out' is misconceived. It flies in the face of both previous judicial logic in this well trodden path of selective forced redundancies, and the proven facts at BA for its selection systems.
15) Returning to the employer's `Outline of Submissions by Pacific Coal Pty Limited' dated 3 February 1999 for a moment, it follows in the present cases that the AIRC is entitled to and should rely upon this Outline to find the selection for retrenchment process necessarily involved the PERs. This finding is undeniably supported by the most cursory examination of the employer's statements served and filed at the same time as the employer's Outline. A 'fair go all round' is required in the conduct of the hearing, although the employer in its year 2000 contentions has continually abandoned any real recognition or understanding of this statutory requirement.
16) Moreover, the employer either did not read or chose to ignore (because the evidence is unanswerable) the multiple admissions found in the oral evidence and documents its own witnesses as summarised in the applicants' submissions, namely:
a) The evidence set out in the Applicants' Introduction (para 11 at pp 7-10) and
b) The evidence proving the unreliability of where Mr Bates denied the pivotal part of the PERs even though he was not involved in the PERs and the G block meetings where the scores out of 40 were allocated (para 4 b) iii) F29)
TRANSLATION OF PER SCORES AT G BLOCK MEETING
17) In the employer's `Introduction to submissions for each individual Applicant' and under the heading `The alleged translation ...' (p 5 ) the employer tries to downplay Mr Keag's two `versions' as being narrow and technical. Accordingly, the answers Mr Keag gave initially in answer to the Commissioner's questions confirm that the witness later changed his evidence upon his realisation of the unsustainable position he had set out for the employer. Even Mr Keag's second version shows that the PERs were the substantial and operative reasons for the `Past Performance' requirements:
18) In any event, Mr Prebble accepted that the first version of Mr Keag was in general terms true, but there were said to have been some specific (unrecalled) examples where that was not the case.
19) Furthermore, in an attempt to defend the G-block meeting for the Production MRU on 22 June 1998, Mr Yeates said:
a) As seen above, in annexure A1 to his first statement his early July 1997 `Records of Discussion' records `Explained the historical performance criteria was the same as the PERs except the score range was 1 to 5, not 1 to 3. Explained the judgment was made based upon the last 18 months - 2 years (last 3 PERs) and any applicable records of behaviour before this period'. (emphasis added)
b) For Mr Cusack `We went through each of his PER's and discussed how they were used in the final scoring system for retrenchment' (annexure A1 to his first statement) (emphasis added).
c) `Future capability assessment was made against matrix criteria in the future requirements. The superintendents and I used previous behaviours and performance plus the rate of change in behaviour and performance over the last 18 months or so as input to our decision' (para 175 pp 23-24 first statement) (emphasis added).
20) As will be seen below, the consistent evidence is that the so-called selection scores for the scores for the 8 criteria were `massaged' by Messrs Yeates, Keag and Thompson (and also it seems Mr Prebble) to what they believed to be right. However all of these employer witnesses admitted that they had limited exposure to employees on shift and would not be in a position to complete PERs. It follows the capability assessments or the 8 criteria, including the `Future Requirements' were made by Manager Yeates, Superintendent Thompson and Superintendent Keag based on the following:
a) Undeniably it included the employer's perception concerning previous so-called behaviours and performance as grounded in the three PERs including the scores.
b) In the case of some applicants, it included some previous so-called behaviours and performance outside the periods of the three PERs, but Mr Yeates in what he told the applicants in early July 1997 had already qualified this to where there was `any applicable records of behaviour before this period'. The employer's statements contain some previous (or past) so-called behaviours and performance outside the periods of the three PERs, for example, the allegation of slow driving made by the employer against Messrs Appleton and Finger in the early 1990's.
c) The alleged rate of change in so-called behaviour and performance over the three PERs (ie the last 18 months). Thus, the employer's scores for the `Future Requirements' necessarily considered the past performance or conduct of an applicant in the three PERs as an indicator of the applicant's future capability or capacity.
21) The cold hard objective facts provide compelling proof of how the employer's systems operated unfairly on CFMEU award employees and were subject to bias and/or were manipulated by the company in contravention of the test propounded by the AIRC Full Bench in CFMEU and AFMEPKIU v Curragh Queensland Mining Limited Print R8490 at para 79. Those facts include for example:
a) The `black list still to go'. Has there ever been a previous industrial case where the applicants have been able to prove that the employer used such an expression in selecting individuals for termination?
b) The 21 October 1997 communication evidenced by Mr Riordan's records, and the changing of the meaning to an opposite.
c) Only 2 employees got off the `black list still to go' or off the `Black list re Retrenchment Process', namely Mr Cec Mooney (coal plant) on 3 February 1998 and Mr Frank Scott (driller in Mine Services) no later than 14 April 1998. See the Chronology in F4 and the `Pool of alleged 'Performance improved'` in F5 pp 35-38. Nine of the applicants were from Overburden and Supervisor Campbell admitted that nobody got off the list to be retained.
d) Sending most of the applicants to the Mine Services chain gang or, putting it a different way, to King Browne's `snake pit'. Mr Barnes summarised the position ` ... most of us had meaningless jobs for a fair bit of it (PER3) so if it wasn't a joke what chance did we have to improve?' (FRX917 L8).
e) The ticks and crosses on the 1997 and 1998 Guidelines documents show that the ratings given to certain applicants were never justified as applicants did, in fact, meet the unilaterally introduced employer expectations. Why did the applicants still receive 1 for a PER criteria?
f) Mr Crooks candidly admitted the overlap and multiple use by the employer of conduct and performance allegations and criticisms from the PERs by the employer in the `Past Performance' requirements and the `Previous Performance' requirements for Messrs McGuiness and Walsh. See also the capability assessment forms of Mr Riordan in General Attachments 26 and 27 in ex PC8. Thus, the employer's refrains, such as `It is not suggested by the Applicants that there is any connection whatsoever between the four future requirements and the PER system ...' and `There is no cross-examination of any employer witness which would cast doubt upon the accuracy of the scores attributed to the Applicant for the four future requirement criteria ...' (see, for example, Mr McGuiness p 7.6) does not even warrant the explanation of being a blinkered approach by the employer. Rather, it is an employer submission made in blind ignorance of the evidence in the present proceedings, including the cross-examination of Supervisor Crooks and the content of the employer's own rating documents, and demonstrates that the employer still persists on calling black as white.
. . . . .
25) The evidence as to the current situation at BA reveals the new employer 'machoism' of 'just sack them'. The employer kept a `black list' against applicants who exercised a fundamental liberty in an Australian work place by way of either expressing a different point of view on work place issues and/or claimed their statutory entitlements. The employer sought to control and eliminate these liberties and statutory entitlements where even under the WR Act it was contrary to principal objects including the employer and the employee determining employment matters (s 3(b)) and `fair and effective agreement-making' (s 3(e)). The personality of applicants also had a bearing on how certain employer raters perceived them.
26) Examples proven in the evidence show where they were part of the reasons for the selection for termination of an applicant it means that the reasons have been shown to be incurably harsh, unjust or unreasonable. Even using the employer's (erroneous) reference to `moral values and prudential considerations current in the community' in Gregory v Phillip Morris (1988) 80 ALR 455 (Jenkinson J), a reasonable person would reply that `of course' it is unfair to use as any part of the reasons to select an employee for termination these employer reasons . . . . .".
[98] The submissions in reply then provided examples of the above allegation which I do not intend to repeat hereunder other than for one example which is indicative of the thrust relied upon by the applicants. The example reproduced relates to Mr Walsh and Mr Mannion:
"a) PP 52-62 as part of 8.8.4.
b) `There is compelling and consistent evidence from the Applicant himself, that the criteria in the PERs were important for persons working in a mine' (see, for example, Mr Kelly p 31).
29) However, a proper perusal of their answers that the employer relies upon show that there is no real and sustainable factual foundation to this standard employer submission. The employer engaged in the folly of asking the questions in a cloud of generality and failed to cross-examine on the specific criteria used at BA. The 4 criteria in the PERs, the 36 factors or bullet points on the PER form, the suffocating multiplicity of expectations in the (secret) 1997 and/or 1998 Guidelines, the (secret) `Unacceptable Behaviour' document, the (secret) `Examples of where employees have attained the rating 3 in their PER's', the `Past Performance' document and/or the `Future Requirements' document were not used in this line of cross-examination of the applicants.
30) Mr Walsh said he did not accept the criteria were ever appropriate ones for determining who should be retrenched (RX601 L1).
31) Mr Allen himself said to Mr Mannion, in asking the questions, ` ... I'm just talking generally, Mr Mannion' (p 56.2). Mr Allen also in his questions to Mr Kelly fully acknowledged he was doing no more than asking generally (XX210 L17). The invariable approach of the employer was to ask meaningless questions, as the questions were not put in the context of the employer's actual systems at BA, but at large. The general appellation of the names of the 4 PER criteria, namely, Safety, Personal Effort, Skills and Teamwork, are going to be defined and interpreted by different people in any number of different ways. The suffocating multiplicity of expectations in the (secret) 1997 and/or 1998 Guideline for each of these 4 criteria confirm how the employer's own ideas of what they meant changed from PER1 to PER2.
32) As seen below, by analogy, the AIRC has found that a proper opportunity to respond means giving an employee the specific and substantive reasons, rather than an opportunity using a general appellation or one clouded in generality - see, for example, Fischer v Telstra Corporation Limited Print R2558 (1 March 1999) (Ross VP, Duncan DP, Redmond), G McKenzie v Imperamada Pty Ltd Print S0628 (Jones C) (3 November 1999) and Swain v Ramsey Food Packaging Pty Ltd Print S2209 (Jones C) (24 December 1999).
33) In any event, an insurmountable bar for the employer's unilateral process is that the employer had legal obligations under its contracts with the applicants. The employer was legally obliged under each contract of employment to get the agreement of the CFMEU to any alternative selection criteria or otherwise seniority had to be applied by the employer at BA for a reduction in hands......".
[99] Reference was made to the term "variation among assessors" and alleged inconsistencies in the PER system as set out hereunder:
"36) . . . . . No Procedural Fairness Or Due Process' (F2 pp 49 - 66), the flaws and inconsistencies in the employer's systems and in particular confirmation of what Ms Knox called `variation among assessors', include, are set out, including:
a) Inadequate employer training for assessors.
b) Inconsistent employer treatment of the dot points on the PER form appearing below each of the four criteria.
c) Inconsistent use of the preparation form for PER1.
d) Inconsistent use by the employer of its `Guidelines' documents for PER2 and 3.
e) Employer comments do not justify particular ratings in PERs.
f) Inconsistent application of the alleged automatic 1 rating.
g) Arbitrary and capricious use of reported safety matters
h) Dredging up matters from the past outside the PER review period.
i) Most of what occurs to us (including at work) is not contained reliably in memory.
j) Inconsistent application of the 3 PER's to rate on `Past Performance' requirements in the so-called selection process.
37) The employer when faced with admissions about these inconsistencies made by its own senior employees now describes them as `illusory'. See, for example, the use of `majority' and ticks and crosses on the incomplete 1997 or 1998 Guidelines documents for PER2 and PER3:
38) There is nothing illusory about the distortions and backflips in the employer's case illustrated in cross-examination and the applicants' submissions. See C1 of the applicants' submissions in `Inconsistent use by the employer of its `Guidelines' documents for PER2 and 3' (F2 pp 56-8).
39) Far from being illusory, the contradictions in the employer's case illuminate the employer's own forensic failures. For example, in relation to the PER preparation documents, Mr Gardner admitted that if there was no comment and a tick it means a person meets expectations (F29 para 6 i)).
Q And when you tick things that means `yes' doesn't it?---Yes, that's right.
And when you cross things it means `no' doesn't it?---Yes that's right (Mr Campbell XX3040 -1).'
(After looking at the ticks and crosses) `Q Well, that means on any view, Mr Kelly, met the majority of the expectations of the employer for `personal effort', doesn't it?---For the majority of them, yes (XX3055 L13).'
55) In other words, the unfair operation of the employer's systems is shown by its failure to avoid the pitfalls acknowledged in its own methodology. It should be noted that these pitfalls were set out in the secret document of Mr Keag which was only disclosed by the employer in 1999 when serving the General Attachments folder now marked ex PC8. P & E employees, unlike Supervisors and above at BA, were never given this type of information and instruction to help them understand and/or challenge the employer' systems. The employer now suggests that reasons justifying the termination of applicants include where an applicant did not ask a Supervisor how to improve performance from PERs or was not forward in requesting assistance (see, for example, Mr Appleton pp 23-13). The employer is putting the cart before the horse, if one accepts the obligations of the employer set out in the employer's own methodology and this is particularly the case where the P & E workforce were not even told what was in the employer's PER cart.
EMPLOYER'S SUGGESTED TEST?
56) An employer refrain in its submissions is that the applicants have to show that they were not one of the bottom 16 ranked employees and also that the applicants failed to lead evidence by which it can be concluded that even 1 of the 180 employees selected for retention performed less effectively than the applicants (see, for example, Mr Kelly pp 5-6).
57) It is a principle without any accepted pedigree as shown by the following:
58) The principles in relation to unfair dismissal applications are as set out in the applicants' submissions on No Due Process and Procedural Fairness (F2) and in the submissions in reply. Put simply, a denial of Due Process and Procedural Fairness can be enough for an applicant to succeed.
59) The principles in relation to unfair dismissal applications as set out in the applicants' submissions on No Objective, Accurate or Fair Ranking in the PERs and/or Selection for Redundancy (F4).
60) In particular, in AIRC cases like Windsor Smith v Liu and Others Print Q3462 (Giudice P, Polites SDP & Gay C and Brooks and Others v Australian Dried Fruits (1998) 84 IR 33 (Simmonds C) applicants have been entitled to relief in selective redundancies on satisfying tests nothing like that propounded by the employer
61) Wilcox J in Addis International Pty Ltd v Allen (1997) 74 IR 262 at 268 said the Court does not have the necessary evidence to enable a choice to be made between which of two employees an employer should have preferred. Nevertheless, the applicant was entitled to relief.
62) As seen above, establishing inconsistencies in the employer's systems is an obvious way for an applicant to show:
a) That the employer's system of selection was so flawed that it resulted in a termination that was harsh, unjust or unreasonable;
b) That that system did not afford employees a `fair go all round"; and/or
c) That the way in which the system was applied to the individual resulted in a termination that was harsh, unjust or unreasonable;
d) That the way in which the system was applied to the individual did not afford that employee a `fair go all round'."
[100] The submissions in reply then turned to the reply to be made on behalf of each applicant to the allegations made against each individual applicant. I do not however intend to repeat each and every reply but have included as an example the following which relates to Mr Albert as it is indicative of the structure of reply for each other applicant. In each particular case, there was reliance upon the claim that the Pacific Coal Year 2000 submissions, in regard to each applicant are misleading and misinterpret the totality of the evidence in relation to each applicant:
"APPLICANTS' REPLY RE MR ALBERT
1) The Applicants reject the respondent's submissions and rely upon the Applicants' primary submissions. The Company's Closing submissions in relation to Mr Albert are misleading and misrepresent the totality of the evidence in relation to his application.
2) The overall picture presented by the applicants' primary submissions in relation to Mr Albert was one of an employee, in relation to whom, the employer had little evidence with which to substantiate complaints about his actual work performance. That picture is confirmed by the employer's submissions, which are remarkably lacking in concrete examples of poor performance on Mr Albert's part (as opposed to matters such as his absences by reason of his injury and personal matters).
SAFETY
3) Mr Albert scored 2 out of 5 for Safety (or `Sometimes Meets Expectations'). In the PERs he received three 2's or `Meets Expectations'. Mr Albert did not get the benefit of the translation described in the testimony of Mr Keag. The employer's conduct and capacity allegation against Mr Albert in this regard should not be accepted as sustainable.
4) The employer submissions do not point to a concrete example where Mr Albert's safety performance justified a rating of anything less than one indicating he met expectations. The employer's submissions rely on the fatuous comments in Mr Albert's PERs, such as that he could do more to suggest improvements. The employer has omitted to note that its own case failed to substantiate the comment. One illustration of this is the employer's reliance on the comment `provide more detailed explanation in the defects book', when the applicants' submissions exposed how the employer, despite being put on notice, was unable to provide any example to illustrate the allegation.
5) In the face of the above inconsistencies, and in the absence of a rational and acceptable basis for concluding that Mr Albert's safety performance sometimes did not meet expectations, the Commission should decline to find that there is any basis to the capacity and conduct allegation made against Mr Albert in this regard.
TEAMWORK
6) Mr Albert scored a 2 out of 5 for Teamwork (`Sometimes meets expectations'). The poverty of the employer's submissions are illustrated by the employer's attempt, in trying to justify this rating (pp 7-8) to rely upon the following ill-founded examples:
a) The comment in PER 2 that Mr Albert should `use time cards accurately'. Mr Albert gave uncontroverted evidence that Mr Campbell admitted, in the 2nd PER interview, something to the effect of `I know you use them correctly Mitch, but this is something we want to put on everyone's PER to get them using the system properly.' (ex CFMEU 43, 2nd statement, para 11). This was confirmed in Mr Campbell's supplementary statement at paragraph 12, to the effect that he considered Mr Albert's use of time cards `satisfactory', and that he relied upon other matters in scoring Mr Albter a 1 in that catagory (ex PC 59).
b) The comment in PER 2 that Mr Albert should `openly propose improvements to other team members', when, in cross-examination Mr Campbell was forced to admit that he could provide no concrete example to support the allegation.
7) The examples relied upon by the employer are so demonstrably unreliable, that the Commission should decline to consider them valid reasons related to Mr Albert's conduct and capacity warranting his termination.
SKILLS
8) Mr Albert scored 2 out of 5 for Skills (`Sometimes meets expectations'), despite having scored two 2's in the 2 PERs immediately prior to his retrenchment (bearing in mind Mr Albert's extended absence throughout the first PER period due to his injury).
9) The employer does not point to any concrete, substantiated examples of Mr Albert's work performance warranting anything other than a rating at least consistent with his PER ratings that he consistently met expectations for this area. The employer has not and cannot deal with the apparent improbabilities and inconsistencies in the evidence of its own witnesses and documents. S 170CG(3)(e) arises as a relevant matter where the employer's inferences could not reasonably have been drawn.
PERSONAL EFFORT
10) In the Company's closing submissions at page 11, the employer purports to set out an excerpt from the transcript of Mr Albert's cross-examination (at page 658) said to demonstrate a concession by Mr Albert that the employer was justified in adopting the course it took.
11) An examination of the actual transcript shows that the employer has not faithfully reproduced what appears at the page reference provided. The employer has failed to indicate where the employer has omitted parts from the passage purported to have been quoted, and in particular, an answer from Mr Albert to a question whether he understood that he scored a 1 because of the final warning:- `I know that it was because of the final warning, but I still disagreed that I had broken their code of conduct because I hadn't stolen nothing from Blair Athol'. Significantly, at no point was it suggested squarely to Mr Albert in cross-examination, despite an abundance of opportunity, that he had in fact stolen the relevant material from the company. The thrust of the company's cross-examination and submission was to the effect that the fact of Mr Albert pleading guilty to the `possession of goods reasonably suspected of being stolen' was reason enough for the company, regardless of whether it is established that a theft actually took place.
12) A further illustration of the employer's misrepresentation of the evidence is the submission at page 12 that `The Applicant admitted that he was warned on numerous occasions that he should not leave his place of work when the dozer was ready to operate'. For that submission the employer cites T648: 20-21 and Exhibit PC 13. Those citations do not provide support for the employer's submission about numerous warnings, nor is support offered for the later assertion that Mr Albert admitted it had been explained that the matter would result in him being marked lower for personal effort. Neither transcript page 648, lines 23 and 24 (which is cited) nor any of the surrounding evidence in cross-examination provide support for such an assertion.
13) It would appear that rather than dealing with the evidence on the matter, including that of Mr Campbell, whose evidence related to two incidents, and that of Mr Albert, who disputed the employer's complaint about his conduct in taking the initiative to re-stock the crib hut when his dozer was being seen to by the fitter, the employer has instead elected to obfuscate. Most importantly, the employer avoided the evidence of its own witness, Mr Campbell, where he admitted that the enthusiasm demonstrated by Mr Albert was the sort of conduct which warranted the awarding of a `3' score (Tcpt, XX 3108, 3109)
`ADAPTING TO CHANGE'
14) The employer provides no specific allegation to warrant Mr Albert's score of 2, which translates as `Has some trouble adapting to change'.
15) An objective analysis of the evidence means, where the employer cannot point to any specific evidence of substance concerning past conduct or performance of the employee as an indicator of likely future performance and faced with the apparent improbabilities, inconsistencies and incredibility's in the evidence of the employer's own documents that the employer's rating is incorrect for this criteria. In the absence of any such example or evidence, the Commission should conclude that the employer's rating is incorrect. The evidential matters which point to Mr Albert's ability to cope with change included his good performance in the use of time cards and his willingness to train on the dozer.
`CONTRIBUTION TO IMPROVEMENT'
16) The employer, in relation to this criteria, again wheels out the allegation that Mr Albert was unreliable. The employer's multiple citation of this allegation demonstrates the inherent unfairness in its application of its system.
17) The employer's submission includes an allegation that Mr Albert admitted that although he was paid an extra half an hour for hot seat changeovers he would often leave his shift early (at page 15). Again the employer's submission does not accurately reflect the evidence in the passage cited, and confuses two answers, the first which acknowledges an incident where Mr Campbell disagreed with Mr Albert parking up the dozer near the crib hut (lines 9-10) and the second which simply acknowledged that employees were paid an extra half hour to effect a hot seat change. Nowhere is there any basis for the submission that Mr Albert often left his shift early.
NO ADEQUATE EMPLOYER NOTICE (pp 19-21, 23)
18) The employer in its submissions denies that `the employer did not establish in advance, publish, widely distribute, and explain the PER's objectives and standards to Mr Albert but the three pages of `general' employer submissions are bereft of reference to any specific evidence of substance, such as the following:
a) PER1 was dated 31 October 1997 by Mr Gardner. The PER1 review period was from 1 January 1997 to 30 June 1997. The PER system was introduced retrospectively by the employer and not in advance.
b) Mr Albert's evidence about the first PER discussion and its brevity ((XX 636, line 22ff).
c) Mr Campbell's admission in cross-examination about his reluctant approach to discussing the issues in the second PER".
Conclusions
[101] In reaching conclusions which may form the basis of findings upon these applications I have taken account of the clear distinction between the respective positions advanced by the parties as to what should and should not be considered in determining whether or not the grounds as to harsh, unjust or unreasonable termination advanced in support of the individual applications have been made out.
[102] In taking that into regard I have also necessarily considered the behaviour of the applicants and the CFMEU as opposed to the behaviour of Pacific Coal and its management staff during the three PER periods of assessment by way of the PA system.
[103] This PA system had, as its centrepiece, three PER ratings periods of six months for each of the individuals who made up the workforce used to determine who should be selected for redundancy as different to what Pacific Coal said below in its Year 2000 submissions:
"a) `It is the retrenchment process and Exhibit PC74 which the Commission should focus its attention upon in deciding the matter. It is not the PER system, for that was not the system which was used to select employees for forced redundancy' (pp 6-7).
b) ` ... This case is not about the PER system. The fact that so many days of evidence were devoted to a close examination of the PER system was because the Applicants, it is submitted erroneously, decided to conduct their cases this way. Exhibit CFMEU74 was prepared having regard to 8 criteria. Only 4 of those criteria reflect the criteria in the PER system' (6.3 p 25). The two emphasised parts of the employer's recent contentions contradict each other and belie the tangled web within which the employer has caught itself as it struggles to come to grips with its inability to put the smashed pieces of its systems together again.
c) `In any event the PER system is not on trial here, for it was system designed to promote improved performance. The Commission must focus on the appeal process to the General Manager, Mr Bates' (1.4 pp 29-30).
d) `The process by which the Applicants were selected is outlined above. The PER system was an entirely separate process designed to improve performance. The 'verification' of the PER scores is therefore irrelevant' (8.12.4 pp 92-3).
e) ` ... the PER system is not relevant because it did not from the basis of the forced redundancy process, which was a separate and distinct process' (9.4.3)".
[104] My consideration of this has also included on balance which construction of the evidence and supporting authorities relied upon by both parties I should prefer.
[105] The submissions made by Counsel for the applicants contained allegations insofar as the conduct of some of the Pacific Coal witnesses, when giving evidence, to the extent that it was suggested that some of such witnesses committed perjury and should be referred to the Director of Public Prosecutions (DPP) and that generally the evidence of the Pacific Coal witnesses was so unreliable that this Commission should pay no regard to such evidence.
[106] However, in the alternative, I have been asked to accept the applicants as having given truthful evidence. In turn, Pacific Coal submitted that this Commission should accept that its witnesses were truthful and that there should be no adverse finding about the evidence presented nor should this Commission entertain referral of any Pacific Coal witness to the DPP insofar as the perjury allegations are concerned.
[107] It is not this Commission's intention to refer any witness who gave evidence in these proceedings to the DPP as other avenues are available to a party if it wishes to pursue issues surrounding such allegations.
[108] I have considered what both parties have had to say on the question of the evidence given by witnesses for the parties and I intend, where I believe that it is appropriate and or necessary, to refer specifically to a witness and his or her evidence.
[109] Attention was also drawn to the question of hearsay evidence and the weight which should be attached to this. This arises from a submission about what was claimed by the applicant's Counsel to be a failure by Pacific Coal to cross-examine applicants upon issues which it then sought to lead in evidence from its own witnesses.
[110] This submission, to that extent, sought reliance upon the Rule in Browne and Dunn (1894) 6 R 67 which was quoted extensively in support of such allegation.
[111] During the course of these proceedings I had cause to issue a decision which made reference to this question in Print S0195 of 18 October 1999 and nothing put following this by Pacific Coal has convinced me that I should resile from the point of view expressed therein as to how I would view and give weight to hearsay evidence.
[112] Essentially the issue in this matter is that Pacific Coal relied on claims that the terminations were based upon redundancy emanating from operational requirements as a defence against the claims of the applicants submitting that:
"The employment of employee may be validly terminated for a reasons or reasons related to the operational requirements of the employers business and/or for a reason related to the employee's capacity or conduct, or for reasons of both kinds. . . . . ".
[113] This requires a consideration of and examination of whether or not in all of the circumstances the selection of the applicants for termination, albeit that such were upon operational requirement imperatives, offends the principles of selection of each applicant to the extent that such represents a "valid reason" and is representative of a "fair go all round" and are not terminations which could be described in all of the circumstances as "harsh, unjust or unreasonable".
[114] Given that the applicants' terminations were based upon a claim of redundancy brought about by operational requirements, under all of the circumstances of such selection for redundancy, was such capable of scrutiny revealing that this was as an end result of the application of an evenhanded process for selection applied equally to all of the employees by way of a fair selection process? To that extent could it be said that the terminations do not offend the concept of a valid reason and are also representative of a "fair go all round" to both the employer and the employee.
[115] Further, were the terminations not capable of attracting the description of harsh, unjust or unreasonable which, after all, was the reason for the filing of the applications, the subject of this decision.
[116] Accordingly, the upside of that would therefore be terminations representative of a valid reason, and ones which could be observed as providing a fair go all round and not of a harsh, unjust or unreasonable character.
[117] This requires a consideration of the circumstances to the extent that I could be satisfied that either Pacific Coal does not have a case to answer or alternatively it does have a case to answer.
[118] It seems to me that Pacific Coal had the managerial right to reduce its workforce and to rely upon operational requirements as outlined in its submission to do so. However, of its own volition in selecting those to be made redundant from its Blair Athol mine, even though this was based upon operational requirements, Pacific Coal chose to rely upon a selection method based upon PA's which in turn relied upon an associated PER process to determine the persons from its workforce who should be selected for termination upon operational grounds.
[119] This necessitates that the circumstances of each applicant's termination and application of such associated PA's and PER process to achieve this be scrutinized by this Commission with a view to assessing whether or not, having regard to section 170CG(3) of the Act, the redundancy selection process and consequent termination offends section 170CG(3) of the Act and, if so, to what extent.
[120] An assessment of the evidence and submissions reveals significant disagreement between the parties, which can readily be seen from the submissions of both parties. Clearly, what each party has submitted as being the appropriate matters to be addressed in reaching a determination upon the applications, is a long way apart.
[121] In the submissions in reply for the applicants, issue was taken with the contentions of Pacific Coal as contained in its Year 2000 submissions, wherein such contentions are described as "Another Employer Recant" by way of:
"6) The desperate attempts of the employer in its submissions to distance itself from the PERs speaks volumes of its own recognition that the applicants have decisively proved on the evidence before the AIRC that the applicants were never accorded a `fair go all round'.
7) Examples of its most recent contentions in February 2000 include:
a) `It is the retrenchment process and Exhibit PC74 which the Commission should focus its attention upon in deciding the matter. It is not the PER system, for that was not the system which was used to select employees for forced redundancy' (pp 6-7).
b) ` ... This case is not about the PER system. The fact that so many days of evidence were devoted to a close examination of the PER system was because the Applicants, it is submitted erroneously, decided to conduct their cases this way. Exhibit CFMEU74 was prepared having regard to 8 criteria. Only 4 of those criteria reflect the criteria in the PER system' (6.3 p 25). The two emphasised parts of the employer's recent contentions contradict each other and belie the tangled web within which the employer has caught itself as it struggles to come to grips with its inability to put the smashed pieces of its systems together again".
[122] As a further example of the above, an extract of the evidence of Rod Bates was raised by way of the following:
"c) `In any event the PER system is not on trial here, for it was system designed to promote improved performance. The Commission must focus on the appeal process to the General Manager, Mr Bates' (1.4 pp 29-30).
d) `The process by which the Applicants were selected is outlined above. The PER system was an entirely separate process designed to improve performance. The 'verification' of the PER scores is therefore irrelevant' (8.12.4 pp 92-3).
e) ` ... the PER system is not relevant because it did not from the basis of the forced redundancy process, which was a separate and distinct process' (9.4.3)
f) `It is fair to say that in selecting the Applicants the PER's were relied upon to a greater or lesser extent by the various managers of the Respondent. However, this in and of itself does not make them the same process; the differences referred to about this make the conclusion inescapable.' (11 p 174) (emphasis added). Once again, the employer's year 2000 contentions are internally contradictory and belie the tangled web within which the employer has caught itself".
[123] Mindful of the evidence and the submissions and specifically in the face of the above, I am of the view that Pacific Coal does have a case to answer as to whether or not the termination of each of the applicants in all of the circumstances was one representative of a valid reason, reflecting a fair go all round and was not a harsh, unjust or unreasonable termination.
[124] The applicants' submissions referred to above are an accurate description of an attempt by Pacific Coal to direct attention away from and separate out the PA's and PER process to the extent that Pacific Coal submitted that this Commission should not give weight to the applicants' claims as to the unfairness of the PER system and its unfair application in selecting each for termination.
[125] Also requiring consideration is the extent to which, in all of the circumstances, section 170CG(3) of the Act needs to be applied when assessing the appropriate criteria for the purpose of determining the arbitration of these matters. Obviously, whilst there are implications capable of having some universal application to the circumstances generally, because each application involves a distinct individual situation, an examination as to each individual applicant's circumstances is also required.
[126] Certain obligations are imposed upon this Commission in determining whether or not an individual's termination was harsh ,unjust or unreasonable and requires consideration of subsection 170CG(3)(a) to (e) which provides:
"(a) whether a there was a valid reason for the termination related to the capacity or conduct of the employee or to the operational requirements of the employers undertaking, establishment or service;
(b) whether the employees was notified of that reason; and
(c) whether the employee was given an opportunity to respond to any reason related to the capacity or conduct of the employee; and
(d) if the termination related to unsatisfactory performance by the employee_whether the employee had been warned about that unsatisfactory performance before the termination; and
(e) any other matters that the commission considers relevant".
[127] I am obliged to have regard to each of the elements contained within this section of the Act to the extent that each must be treated as a matter of significance in the decision making process. (See Edwards v Giudice and Others (1999) 169 ALR 89, at p.92 per Moore J; King v Freshmore (Vic) Pty Ltd, [Print S4213], 17 March 2000 per Ross VP, Williams SDP and Hingley C).
[128] In determining for the purposes of the arbitration, whether a termination was harsh, unjust or unreasonable, I am attracted to the following in part extraction of rebuttal, on behalf of the applicants, against the Pacific Coal position taken from the CFMEU's submissions in reply:
"EMPLOYER'S SUGGESTED TEST?
56) An employer refrain in its submissions is that the applicants have to show that they were not one of the bottom 16 ranked employees and also that the applicants failed to lead evidence by which it can be concluded that even 1 of the 180 employees selected for retention performed less effectively than the applicants (see, for example, Mr Kelly pp 5-6).
57) It is a principle without any accepted pedigree as shown by the following:
58) The principles in relation to unfair dismissal applications are as set out in the applicants' submissions on No Due Process and Procedural Fairness (F2) and in the submissions in reply. Put simply, a denial of Due Process and Procedural Fairness can be enough for an applicant to succeed.
59) The principles in relation to unfair dismissal applications as set out in the applicants' submissions on No Objective, Accurate or Fair Ranking in the PERs and/or Selection for Redundancy (F4).
60) In particular, in AIRC cases like Windsor Smith v Liu and Others Print Q3462 (Giudice P, Polites SDP & Gay C and Brooks and Others v Australian Dried Fruits (1998) 84 IR 33 (Simmonds C) applicants have been entitled to relief in selective redundancies on satisfying tests nothing like that propounded by the employer
61) Wilcox J in Addis International Pty Ltd v Allen (1997) 74 IR 262 at 268 said the Court does not have the necessary evidence to enable a choice to be made between which of two employees an employer should have preferred. Nevertheless, the applicant was entitled to relief.
62) As seen above, establishing inconsistencies in the employer's systems is an obvious way for an applicant to show:
a) That the employer's system of selection was so flawed that it resulted in a termination that was harsh, unjust or unreasonable;
b) That that system did not afford employees a `fair go all round'; and/or
c) That the way in which the system was applied to the individual resulted in a termination that was harsh, unjust or unreasonable;
d) That the way in which the system was applied to the individual did not afford that employee a `fair go all round'". (My emphasis).
[129] My conclusions as to the above extract are that insofar as precedent and the appropriate method of assessing the circumstances which led up to the termination of the applicants as individuals is that this is an appropriate way to consider the individual applicants circumstances by setting the above against the individual circumstances of the applicants.
[130] This, in my view, is consistent with the obligation I have in relation to the matters I must have regard to in reaching conclusions upon these matters.
[131] Obviously to give weight to the above it would firstly be necessary to determine if the application of the PER system was so flawed as to result in an outcome which denied the applicants, as individuals, a fair go all round and offended the valid reason criteria, and in turn was representative of a termination at the instigation of the employer that was harsh, unjust or unreasonable, in that, as raised above:
"62) As seen above, establishing inconsistencies in the employer's systems is an obvious way for an applicant to show:
a) That the employer's system of selection was so flawed that it resulted in a termination that was harsh, unjust or unreasonable;
b) That that system did not afford employees a `fair go all round'; and/or
c) That the way in which the system was applied to the individual resulted in a termination that was harsh, unjust or unreasonable;
d) That the way in which the system was applied to the individual did not afford that employee a `fair go all round'."
[132] If that conclusion emerges, then in turn, this requires as suggested earlier, a requirement to have regard to and consideration of the individual applicants' circumstances against that background, as such proposition represents, in my view, an appropriate approach to these questions;
[133] In having said what I have had to say above, I accept that the issue between the parties about the nature of that which is before this Commission is represented by the following construction placed upon this issue by the applicants:
"63) The employer in its submissions apparently makes a fundamental mistake of assuming that these proceedings are like proceedings of the type which the AIRC (and its predecessors) has been traditionally involved, namely, conciliation and arbitration of inter-state industrial disputes. The present cases are all about the enforcement of individual rights by reference to past events. The Commissioner is exercising a quasi-judicial power which is a fundamentally different power to the arbitral power. (See Federal Court (Wilcox and Madgwick JJ) in Re Australian Industrial Relations Commission; Ex parte Construction, Forestry, Mining and Energy Union (1999) 164 ALR 73 and in particular, paras 72, 73, 74, 79 said . . . . .".
Regard to section 170CG(3)
[134] As mentioned above, as far as the application of section 170CG(3) is concerned, it has been necessary to consider, given the circumstances as to which elements of subsections 170CG(3)(a) to (e) require application, after a consideration of the reasons advanced by Pacific Coal for the selection and termination of the applicants.
[135] To assist me in reaching a conclusion upon this question I have reconsidered what Pacific Coal had to say in relation to this issue. To that end there seems to be a lack of consistency in that, on the one hand, it was submitted in the following extract from the Pacific Coal Outline of Submissions of 3 February 1999 (Exhibit Pacific Coal 21), that:
"1.2 In particular, in relation to the matters the Commission must have regard to under section 170CG(3) of the Act, the Respondent submits:
. . . . .
(c) Each of the Applicants was given the opportunity to respond to assessments made that related to their capacity or conduct in so far as they related to the Applicants selection for redundancy. In particular, each of the Applicants was given the opportunity to participate in a performance effectiveness review process (`PER') and was given an opportunity to respond to their selection for redundancy.
(d) To the extent that the selection for redundancy related to the comparative unsatisfactory performance by the Applicants, each of the Applicants had been advised that the assessments made in the PER and their performance would be matters that would be taken into account in deciding who would be selected for future redundancies at BAC ...': (1.2(d))
1.3 Each of the Applicants was made redundant in the following circumstances . . . . . In accordance with the advice that had previously been given the Respondent selected employees for redundancy based on their performance. This performance had been determined by a process which included a reference to the assessment of employees' PER. In turn, the Respondent established selection criteria for redundancy which included performance and other factors related to the future roles at BAC . . . . .".
[136] Under the heading "Redundancy Selection Process Fair", it was said:
"The PER process applied by the Respondent and used in part for the selection criteria is consistent with similar processes used generally, and specifically in Rio Tinto companies".
[137] The only evidence of similar processes used specifically at Rio Tinto companies concerned PA's processes including at Hamersley Iron and Kennecott (Exhibits CFMEU 60 and 61).
[138] Under the heading "Ranking" it was said
"There was more than adequate training of the assessors in both the PER and redundancy selection processes. . . . . The Respondent had informed the employees of the importance of the PER process and that it would be one of the factors taken into account in selecting for any future redundancy . . . . . ".
[139] Under the heading "Procedural Fairness" it was said:
". . . . . The Respondent submits that the Applicants' refusal to assist themselves by participating in the PER process is also relevant".
which is at odds (as pointed out by the CFMEU) as far as the Year 2000 submissions of Pacific Coal in reply are concerned, as referred to above.
[140] The nature of the above extracts taken from the initial Outline of Submissions of Pacific Coal are the ones upon which I intend to concentrate upon. I do not accept the latter proposition of Pacific Coal described earlier above under the heading "Another Employer Recant" as it is clear that the applicants presented a case based upon what Pacific Coal submitted initially in its Outline of Submissions contained in Pacific Coal Exhibit 21, accepting that this represented the terms relating to its case, which the applicants would have to overcome.
[141] It seems to me that whilst Pacific Coal had the right to reduce its workforce and to rely upon operational requirements to do so, that in selecting those to be made redundant of its own volition, it chose a selection method reliant upon both a PA's and PER process it had adopted at the Blair Athol mine to determine which of its workforce should be selected for termination.
Last on/first off implications
[142] Historically, the method of selecting persons in the black coal mining industry for redundancy where offers of voluntary redundancy had not achieved the numbers sought, was to make persons redundant upon the application of "last on/first off"principle. However, such capability was removed from the industry award from 1 July 1998 by way of amendments to the Act which were reflected within section 89A(2) of the Act which regulates allowable award matters.
[143] It seems to me that Pacific Coal, having a knowledge of the history of the last on/first off regime, were mindful of a need to be able to justify any of the selections ultimately made, given that there was potential for long term employees, as opposed to shorter term employees, being included within those ultimately selected for redundancy.
[144] Historically the applicants would have, but for the changes to the Act referred to above, been some of the last to go and would not have been selected in the 1998 workforce reduction at the Blair Athol mine which has led to the applications dealt with herein.
[145] I am satisfied that this was in part some of the reasoning behind the development of the PER system, albeit elements of such were designed to also improve performance and production, but also to create a defensible selection process for redundancy based terminations.
[146] What followed, in my view, was that the PA's and PER system at Blair Athol had a dual purpose as far as the restructuring of the mine was concerned, as it was also the tool to be used to select those to be made redundant. This process was in the knowledge that such would more than likely be challenged where seniority was not applied to the extent of proceedings of the order before this Commission and that application of the PER system would provide a means to justify such selections.
Fair go all round implications and authorities
[147] The issues raised as to the harsh, unjust or unreasonable questions which require consideration, aligned with the fair go all round scenario are, in my view, supported by the following summary and reference to authorities upon this which are extracted from the applicants' submissions:
"b) It may be that the termination is harsh but not unjust or unreasonable, unjust but not harsh or unreasonable, or unreasonable but not harsh or unjust. In many cases the concepts will overlap: Byrne v Australian Airlines (1995) 185 CLR 410 at 465.5.
c) The expression `fair go all round' means it is not wrong to conclude that whether there was a fair go all round in the circumstances was a factor to be taken into account in determining whether the termination was harsh, unjust or unreasonable. `There is little doubt that s 170CA(2) enjoins the Commission to apply basic notions of fairness in carrying out its functions under Division 3. The injunction is not limited to the manner in which the hearing is conducted or the consideration of the remedy to be rewarded but extends to the Commission's consideration of all of the relevant circumstances. Were it otherwise the reference to Loty and Holloway would not make sense.': Full Bench of the AIRC (Giudice P, Polites SDP and Gregor C) in National Jet Systems Pty Ltd v Mollinger Print R3130 at paras 10-13. . . . . .".
[148] I am particularly mindful of the following as it applies to the matters before me:
"d) Two particular facets of the statutory framework are relevant.
i) The first relates to the objects of Div 3 of Pt VIA of the Act in s 170CA(1) and (2). Section 170CA(2) makes it clear it was intended that in the arbitration of a claim that a termination was harsh, unjust or unreasonable the Commission should ensure that a `fair go all round' is accorded to both the employer and employee concerned.
ii) The second relevant feature of the statutory framework is s 170CG(3). The first point in respect of s 170CG(3) is it clear from the subsection that the existence of a `valid reason' for the termination is a factor which the Commission must have regard. However, it is not the only factor to which the Commission must have regard. Unlike the position under s 170DE(10 of the former Act the question of whether there was a valid reason for the termination is not determinative but merely one factor which the Commission must have regard to in making its assessment of whether the termination was harsh, unjust or unreasonable. The second to be made about s 170CG(3) is that it does not, in terms, limit the Commission's consideration to an application as to whether the employer had reasonable grounds, on the facts at the relevant time, for terminating the applicant. Indeed the requirement in s 170CG(3)(e) to have regard to any other matters that the Commission considers relevant appears inconsistent with this limitation: Australian Meat Holdings Pty Ltd v McLauchlan (1998) 84 IR 1 at 7 - 8 (Ross VP, Polites SDP and Hoffman C)....".
Evidentiary burden
[149] The submissions of the applicants revealed an acceptance of the onus being upon them to show that the terminations were harsh, unjust or unreasonable. However, I accept that Pacific Coal carries the evidentiary obligation to prove the factual issues which support its case and, in my view, the following in part extract of submission made on behalf of the applicants is on point in that regard:
"Evidentiary Burden Falls On The Employer
25) The applicants accept that they bear the onus of showing they have been treated harsh, unjust or unreasonably and have not been afforded a `fair go all round'. It is submitted, however, that an evidentiary burden falls on the employer to prove factual issues in its own case such as the following:
a) The real reason(s) why a particular applicant was allocated a PER score and/or was selected for redundancy.
b) Disputed conduct and capacity allegations made by the employer.
c) Any employer allegation of inappropriateness for reinstatement.
26) The principles behind these submissions are as follows:
a) The reasons of an employer for terminating the employment of an employee are solely within the knowledge of the employer. The employer may state a reason but that reason need not be the actual reason nor need it be the only reason: Johns v Gunns Pty Ltd (1995) 60 IR 258 at 267 (Northrop J). Although this was expressed in the context of Parliament from time to time devising procedures to transfer to an employer the onus of proving the reason for termination, its logical force has obvious application to issues in a reinstatement case.
b) The applicant is required to establish a case for reinstatement, but cannot prove any facts beyond his own knowledge. The facts suggest on their face harshness and unfairness and, in the absence of any suggestion for a reason which would explain his dismissal, it was open to the presiding tribunal member to conclude that an employer's conduct towards its employee was harsh and unjust. Evidence has been adduced in support of the application, which is sufficient to establish a prima facie case of harshness, and thus to call for further inquiry: Western Suburbs District Ambulance Committee v Tipping [1957] AR 273 at 277 (De Baun and Cook JJ).
c) See the authorities collected by Hungerford J in Pastrycooks Union (NSW) v Gartrell White (No 3) (1990) 35 IR 70 at 83-84, including Darling Island Stevedoring & Lighterage Co Ltd v Jacobsen (1945) 70 CLR 635 at 643-644 (Dixon J). Where a respondent in a matter concerning dismissal raises misconduct as a defence or justification then the legal burden shifts in an evidentiary sense to the respondent to establish the facts which are said to ground misconduct: see, for example, Darling Island Stevedoring & Lighterage Co Limited v Jacobsen (1945) 70 CLR 635 at 639, 643, 644 (and note terms of legislation at 635 and at 644), W D & H O Wills (Aust) Limited v Jamieson [1957] AR 547 at 552-553, North v Television Corporation Ltd 11 ALR 599 at 603 and Pastry Cooks Employees, Biscuit Makers Employees & Flour and Sugar Goods Workers Union (NSW) v Gartrell White (No 3) (1990) 35 IR 70 at 83-84.Thus, as a general rule the proof of a negative is not imposed upon a party. Although it is by no means uniformly true, yet it is not usual for the law to require disproof of a fact (for example, it is not usual for the law to require disproof by an employee of an employer assertion that it is impracticable to reinstate)".
[150] The method of selection used to select the applicants for redundancy was always of an order whereby it would be open to challenge and given the existence of the black list and its accompanying connotation "still to go", which became an ongoing reference at some point in time, together with the knowledge of this list by those responsible for rating the applicants, becomes an important and significant issue which, in my view, is not easily swept away in the manner suggested by Pacific Coal.
[151] Specifically in that regard I refer to the following passage from the Pacific Coal submissions:
"Much has been made by the Applicants in their submissions about `black lists' and `black lists still go'. Yet the evidence about the development of this coloured rating list was not successfully challenged in cross examination. The Applicants have done everything they can to sensationalise and beat up the issue of `black lists still to go', however the fact is that they have failed to demonstrate that the rating list related to any factor other than performance.
. . . . .
· The production of the organisational chart by the so called whistle blower witness, Ms Janene Hoch. This Exhibit included the reference to `black lists still to go' and was characterised by the Applicants as a revelation demonstrating that the Company had not complied with the summons and had hidden the existence of a so called black list. However organisational charts were never summonsed, the Exhibit is not a ranking list, and the evidence has demonstrated that the evolution of the terminology `black list' was not sinister.
· The overwriting in Mr Riordan's notebooks of references to black lists. If anyone has been badly treated in these proceedings it is Mr Riordan. He selected the pages which included the overwriting and obliteration. It can hardly be suggested that he was trying to hide this material from the Commission or the Applicants. The changes in many cases were clear to the naked eye and the obliteration stood out like a neon sign. Yet the Applicants seized upon this as some sort of revelation and confirmation of their conspiracy paranoia and quite improperly and inappropriately raised the stakes by suggesting offences under the Commonwealth Crimes Act. In the circumstances it is quite understandable why Mr Riordan then sought independent legal advice and refused to answer further questions on this topic. The Applicants' treatment of Mr Riordan deprived the Commission of the ability for Mr Riordan to explain what was in his notes. It also unfairly deprived the Respondent of the ability to adduce further evidence from Mr Riordan to answer allegations made against it based on the notebooks
But notwithstanding this beat up and sensationalism, the evidence is that the coloured lists were based on performance. There is simply no evidence to justify the assertion that some secret `black list' was created to target the Applicants and target union activists. On the contrary an employee's position on the list changed as their performance changed with the result that some employees on the `black list' are still employees at the Mine. This in itself demonstrates that the conspiracy theory of the Applicants is simply untrue".
[152] However, my view of this is that the reference to "some secret black list" above is accurate as this list was kept from the knowledge of the workforce and the CFMEU and was the subject of an attempt to make such term indistinguishable in Exhibit CFMEU 84. In relation to that, after an examination of the notebooks of Mr Riordan described as Joe's Book (Exhibit CFMEU 84) which comprised of photocopied extracts taken from six Spirax Notebooks, I have reached the following conclusions:
· I reject the above Pacific Coal depiction placed upon the changes made to a number of pages included within such exhibit. This Pacific Coal depiction of such pages asserts that the changes were caused by Mr Riordan, being a chronic overwriter, and that there is nothing more to it than that.
· My rejection of this assertion is on the grounds that my understanding of the term overwriting is that where overwriting occurs, the result is over emphasis of the original written word or words.
· By comparison however, in the instances drawn to my attention, the nature of the overwriting is better described as it was by the handwriting expert as obliteration, as clearly what results is a change to the intent and meaning of what was originally written.
· This is best exampled by a careful examination of the handwriting expert's report as to the words concerned, to see the extent of this.
· An examination of what Mr Riordan wrote within his note books, which were numbered from 1 to 523 for identification purposes with such numbering attended to by this Commission, reveals in my view the following:
▪ An examination of what is at line 4 of page 101 reveals that the initial notes made were: "Blue vs Black";
▪ however an examination of the overwritten words reveals that the note suggests that the above words were "Blue vs Brown";
▪ and at lines 9 and 19 at page 120, in an attempt to attain the context of what is written, I have included the full reference as it refers to PER ratings and reveals, in my view that the initial notes made were:
"PER ratings |
→ |
We have lifted our expectations |
(Org meetg with Supv/Supt) |
→ |
(Communicate this) to everyone |
→ |
Black List are unlikely to achieve 7 or 8 (ie `Meet expectations') | |
→ |
Anyone who was 7 or below and changes to 8 or more JR to review BEFORE interview takes place". (My emphasis) |
▪ however an examination of the overwritten words reveals that the note was made to look to have read:
"PER ratings |
→ |
We have lifted our expectations |
(Org meetg with Supv/Supt) |
→ |
(Communicate this) to everyone |
→ |
Rating List are verylikely to achieve 7 or 8 (ie `Meet expectations') | |
→ |
Anyone who was 7 or below and changes to 8 or more JR to review BEFORE interview takes place". (My emphasis) |
▪ and lines 3 and 6 of page 129 reveal that the initial notes made were:
"Monday 3/11 |
||
1 Ranking of Maint vs Mining |
||
→ |
Process for ensuring that Black List for Maint doesn`t unfairly handicap | |
* When will structure be signed off. |
||
* Coal Plant Maint |
→ |
Advise Black/ Blue List (DY to do) |
* Maint Brown List |
→ |
17 (not 22 fitters) |
2 NOSA Audit |
||
→ |
Job Safe Procedures - Working at Heights, Hot Work (Jane J.?" (My emphasis) |
▪ however, an examination of the overwritten words suggests that the note was made to look to have read:
"Monday 3/11 |
||
1 Ranking of Maint vs Mining |
||
→ |
Process for ensuring that Rating List for Maint doesn`t unfairly handicap | |
* When will structure be signed off. |
||
* Coal Plant Maint |
→ |
Advise Rating/ Blue List (DY to do) |
* Maint Brown List |
→ |
17 (not 22 fitters) |
2 NOSA Audit |
||
→ |
Job Safe Procedures - Working at Heights, Hot Work (Jane J.?" (My emphasis) |
· Such reveals, in my view, attempts to change the intent of what the original writing intended to record.
· Upon examination, the changes to the passages I have examined above reveal a totally different intent and to that extent the description, overwriting, simply does not stand up to scrutiny.
[153] It is clear to me that the whole issue of the black list and/or black list still to go, in its different forms, has led to a significant degree of concern amongst those responsible for the rating of the applicants, even though I note the submission of Pacific Coal that:
"But notwithstanding this beat up and sensationalism, the evidence is that the coloured lists were based on performance. There is simply no evidence to justify the assertion that some secret `black list' was created to target the Applicants and target union activists. On the contrary an employee's position on the list changed as their performance changed with the result that some employees on the `black list' are still employees at the Mine. This in itself demonstrates that the conspiracy theory of the Applicants is simply untrue".
[154] In my view, it is questionable that the purpose of the originating black list was genuinely based upon performance and in any event, what was used to rate performance was the PER system, and the black list seemed to me to have been used as an aid to achieve this end.
[155] The evidence of the Pacific Coal witnesses referred to earlier in an examination of the applicants' submissions is testament to that as there are inconsistencies about knowledge of and application of the black list, yet this was a knowledge known only to Pacific Coal management staff and not shared with the workforce, or the applicants, or the CFMEU.
[156] The impact and implications of the inclusion of and maintenance of an employee's name upon such black list is, in my view, properly characterised by Ms Knox where she said at Exhibit CFMEU 55 at page 4:
". . . . . If knowledge of future retrenchees' identity was widespread, then this may have undermined those employees' chances of getting a fair and unbiased assessment during the second, third and fourth PERs. This issue needs more detailed examination to see how widespread such knowledge was".
and, later in her report at page 28, where she also said:
". . . . . This bias is apparent in that assessors seemed more likely to note down what was wrong with these particular employees rather than respond to descriptors where the employees performance was satisfactory. This may have resulted in an unduly negative view of these employees".
[157] It is clear, based upon the evidence, that knowledge of the existence of the black list and other coloured lists was well known to those responsible for the ratings and in the qualification of such ratings. Importantly, this was something which Pacific Coal did not make known to the applicants, or their union, at any time from the time such list came into existence during the PER review periods. In fact, the evidence makes it clear that it was only during the course of the proceedings before this Commission that the applicants and their union became aware of this.
[158] It is also fair to say that not only were the applicants and their union not told of the existence of the black list nor, for that matter was this Commission made aware of the existence of colored lists which were used as identification of the workforce in a status sense, until it became untenable for Pacific Coal not to do so.
[159] The following construction placed upon this by the CFMEU where it was submitted that:
". . . . . This issue has been examined in more detail by the applicants from the records produced under compulsion and in cross-examination of the employer's case. It can be safely concluded that the knowledge was widespread amongst those responsible for rating the P & E workforce, namely, Supervisors and the management stratum above that level, and the bias and prejudice has been proved to have operated in practice. By way of example, the `21 October 1997 communication' in `Joe's Book', as referred to below, provided powerful evidence of the unfair and biased nature of the employer's PER system".
is an appropriate view to be placed upon this.
[160] This interpretation of the potential for unfair treatment to the applicants is exampled by way of reference to the following extract from page 4 of the statement of Ms Knox:
"This also raises a concern that the decision to retrench was based on the results from the first PER. It should be born in mind that this was also the first time that team leaders were asked to use such an instrument. There is an issue over whether the accuracy of those retrenchment nominations would not have been improved by selecting employees on the basis of second and third PERs. . . . .".
[161] The applicants' submissions to give weight to the above, submitted that:
". . . . . The real nature of this concern is demonstrated by the fact that 12 of the 16 applicants were on the black lists no later than after PER1 (about 11/97). Further, a number of applicants were told by various stratum of management in November 1997 that they had no role in the future operation of BA. Moreover, PER1 was supposed to have been a voluntary process".
[162] In that sense, such an attitude would be contrary to what was held in Gibson v Bosmac Pty Ltd (1995) 130 ALR 246 as referred to in the applicants' Year 2000 submssions as follows:
"d) By way of analogy to Gibson v Bosmac Pty Ltd (1995) 130 ALR 246 at 252 (Wilcox CJ). "...the section imposed an important limitation on an employer's power of dismissal. Ordinarily, before being dismissed for reasons related to conduct or performance, an employee must be made aware of the particular matters that are putting his job at risk and given an opportunity of defence. However, I also pointed out that the section does not require any particular formality. It is intended to be applied in a practical, common sense way so as to ensure that the affected employee is treated fairly. Where the employee is aware of the precise nature of the employer's concern about his or her conduct or performance and has a full opportunity to respond to this concern, this is enough to satisfy the requirements of the section."
e) Moore J in Perrin v Des Taylor Pty Ltd (1995) 58 IR 254 at 256 said the two purposes of the former s 170DC were:
i) To give the employee the opportunity to demonstrate that the allegations have no foundation in fact or they should not be viewed as reflecting the employee's capacity. The latter included, in that case, that there was an explanation for the slow delivery of parts that did not relate to any want of effort on his behalf; and
ii) The employee with whom an allegation has been raised may be able to persuade the employer that, while the allegation is of substance, there are factors that should persuade the employer not to terminate the employment. They may be extenuating personal circumstances or they may involve undertakings about future conduct.".
[163] In that sense, Ms Arnold the expert witness for Pacific Coal, under cross-examination concurred with what Ms Knox had to say on that point as referenced by the following extract from the CFMEU submissions:
"c) Ms Arnold accepted if the 21 October 1997 communication was a decision it would be unfair and, furthermore, the communication would colour, in the sense of potentially biasing or prejudicing, the views of supervisors and superintendents (XX2816).
d) Applicants had already been selected for redundancy prior to 1 July 1998 in contravention of the `reduction in hands' clause in the applicable award and/or in contravention of an earlier `reduction in hands' clause expressly incorporated in an individual applicant's contract of employment.
e) P & E employees had already been selected for retention prior to 1 July 1998".
[164] This then is set against questions of procedural fairness by way of the following extract from the Year 2000 submissions for the applicants:
"A1. ADEQUATE NOTICE - OBJECTIVES AND STANDARDS ARE ESTABLISHED IN ADVANCE, PUBLISHED, WIDELY DISTRIBUTED, AND EXPLAINED
PRINCIPLES IN RELATION TO UNFAIR DISMISSAL APPLICATIONS
12) The applicants in the PER process and/or the so-called retrenchment process were not accorded true procedural fairness and the employer acted in contravention of established principles in relation to unfair dismissal applications as follows:
a) A decision which is the product of unfair procedures may be arbitrary, irrational or unreasonable. The question is whether, in all the circumstances, the termination of employment disobeyed the injunction that it not be harsh, unjust or unreasonable: Byrne v Australian Airlines at 466.2. Procedures adopted in carrying out the termination might be properly taken into account in determining whether the termination thus produced was harsh, unjust or unreasonable: at 468.3.
b) A most recent Full Bench of the Industrial Relations Commission of NSW (Wright P, Walton VP and Redmond C) in Antonakopoulos v State Bank of New South Wales, unreported, 30 July 1999, provides some helpful guidance as to the relevant principles concerning procedural fairness in relation to unfair dismissal applications. The relevant principles concerning procedural fairness in relation to unfair dismissal applications are as follows:
i) A consideration of unfair procedures will be relevant to the determination of the question as to whether a dismissal was harsh, unjust or unreasonable (4.6).
ii) The adoption of, or application, of an unfair procedure may, of itself, result in a dismissal being harsh, unjust or unreasonable (4.9). See also the reference to Brennan CJ, Dawson and Toohey JJ in Byrne at 430.
iii) A failure to afford procedural fairness which causes a substantial and irrevocable prejudice to the employee will often vitiate the decision of the employer and warrant, in itself, a determination that the dismissal was harsh, unjust or unreasonable (and hence establish the basis for a remedy under the Act) (6.9).
iv) A decision made to dismiss made upon the basis of procedures which are unfair and where an innocent explanation is reasonably available will normally constitute a firm and based upon the construction placed on this basis for a determination that a dismissal, so effected, is harsh, unjust or unreasonable (7.1).
v) An unfair procedure may otherwise be a significant consideration warranting the exercise of the Commission's discretion in determining whether a dismissal is harsh, unjust or unreasonable (8.5).
vi) Where procedures are specified in an industrial instrument or by administrative action, a failure by an employer to apply, or to properly apply, those procedures may in appropriate cases, of itself, support a finding that the dismissal was harsh, unjust or unreasonable (9.6).".
[165] The following goes to the question of the appropriate method to engage and involve an employee in the PER process:
"c) `Consultation between employers and employees, preceded by the distribution of adequate information is not only sensible but essential if commerce and industry are to meet the challenge of progress in a spirit of harmony and with some regard human dignity': FCU v Victorian Employers' Federation (1984) 154 CLR 472 at 511 (Wilson J) (emphasis added) and referred to with approval when dealing with applications that redundancies were harsh, unjust or unreasonable in cases such as Quality Bakers of Australia Ltd v Goulding (1995) 60 IR 327 at 334.8 (Beazley J) and Mitchell-Collins v The Latrobe Council (1995) 60 IR 408 at 490.7 (Spender J).
d) The labour Court in Auckland Provisional District Local Authorities Officers IUOW v Mount Albert City Council [1989] 2 NZILR 651 held that:
i) An employer failed in its duties as an employer by not providing an employee with adequate training. An employee did not receive either in-house or external training on management matters, nor was he counselled or advised in respect of area where it appeared he would not cope. Basically, an employee was allowed to carry out his job functions, without adequate supervision or instruction: at 655.6.
ii) By failing to provide an employee with training or encouragement in management skills and in failing to provide any real supervision, the employer breached the term implied into the contract of employment that it would provide all that was reasonably necessary in carrying out the overall purpose of the contract: at 657.3.
iii) The employer failed to provide the necessary co-operation, training and support to enable an employee to carry out his duties: at 658.3.
Performance literature
13) The employer's primary research article recognised this characteristic of Adequate Notice as being part of the Folger 1992 due-process appraisal system: Arvey and Murphy, at 156.7, RX2848 `a summary from some international and well-known experts in the area'".
[166] The following extracts of evidence taken during cross-examination of Mr Bates, the General Manager of Operations at the mine and Mr Yeates, the Manager of Production, were described as admissions supporting the above claim that the applicants were denied due process to the extent that such admissions represented terminations which were harsh, unjust or unreasonable and that support for such construction by way of authority resided within Antonakopoulos v State Bank of New South Wales, unreported 30 July 1999. The alleged admissions have been extracted from the submissions of the applicants under the heading:
"Failures of the employer to provide due process or producedural fairness
14) Mr Bates admitted that:
a) He had the ultimate responsibility to ensure something like the expectations on how the PER system would be administered, as set out in the memorandum of Mr Keag (ex PC8 General Attachment 32), were complied with at BA: XX4482 L15.
b) Q You can look at whether that has been applied consistently and fairly, can't you?---Oh, yes: L22. . . . ".
[167] In relation to the alleged admission of Mr Yeates, this was posed as:
"15) Mr Yeates was asked Q And in your senior position, you accept an employer should be able to be judged by its own administrative standards to see if it acted fairly, don't you?---That's true: XX4329 L1.
16) Thus, in light of the admissions by these two most senior BA Managers, it is submitted that the AIRC is entitled to find that this is an appropriate case where a failure by an employer to apply, or to properly apply, procedures specified by administrative action may, of itself, support a finding that the dismissal was harsh, unjust or unreasonable: Antonakopoulos v State Bank of New South Wales (9.6)".
[168] The questions which arise from the above are reflected within the following extract from the applicants' submissions in reply as to how the PER system and its application should be considered and in that sense is brought into relief as under:
"36) . . . . . the flaws and inconsistencies in the employer's systems and in particular confirmation of what Ms Knox called `variation among assessors', include, are set out, including:
a) Inadequate employer training for assessors.
b) Inconsistent employer treatment of the dot points on the PER form appearing below each of the four criteria.
c) Inconsistent use of the preparation form for PER1.
d) Inconsistent use by the employer of its `Guidelines' documents for PER2 and 3.
e) Employer comments do not justify particular ratings in PERs.
f) Inconsistent application of the alleged automatic 1 rating.
g) Arbitrary and capricious use of reported safety matters
h) Dredging up matters from the past outside the PER review period.
i) Most of what occurs to us (including at work) is not contained reliably in memory.
j) Inconsistent application of the 3 PER's to rate on `Past Performance' requirements in the so-called selection process.
37) The employer when faced with admissions about these inconsistencies made by its own senior employees now describes them as `illusory'. See, for example, the use of `majority' and ticks and crosses on the incomplete 1997 or 1998 Guidelines documents for PER2 and PER3:
38) There is nothing illusory about the distortions and backflips in the employer's case illustrated in cross-examination and the applicants' submissions. See C1 of the applicants' submissions in `Inconsistent use by the employer of its `Guidelines' documents for PER2 and 3' (F2 pp 56-8).
39) Far from being illusory, the contradictions in the employer's case illuminate the employer's own forensic failures. For example, in relation to the PER preparation documents, Mr Gardner admitted that if there was no comment and a tick it means a person meets expectations (F29 para 6 i)).
`Q And when you tick things that means `yes' doesn't it?---Yes, that's right.
And when you cross things it means `no' doesn't it?---Yes that's right (Mr Campbell XX3040 -1).'
(After looking at the ticks and crosses) `Q Well, that means on any view, Mr Kelly, met the majority of the expectations of the employer for `personal effort', doesn't it?---For the majority of them, yes (XX3055 L13)". (My emphasis).
[169] The appropriate test to be applied to the PER system and its application to the applicants is properly, in my view, founded in the following extract taken from the applicants' submissions in reply:
"10) The AIRC should apply the same approach to the more recent employer attempt to recant on its submissions made 12 months earlier at the beginning of the case as these were concessions that the applicants have been entitled to rely upon from the time they were given. In other words, the case was conducted on the employer's own territory which undeniably included the PER process as a pivotal issue".
and is an important principle in my consideration of that which I must consider and have regard to insofar as the application of subsections 170CE(3)(a) to (e) to the circumstances before me.
[170] In terms of what I intend to consider in that regard, I have the view that not only are the applicants entitled to rely upon what Pacific Coal had to say in its Outline of Submissions of 3 February 1999 (Exhibit Pacific Coal 21) made at the commencement of these proceedings, but for that matter, so is this Commission and I adopt the following principles raised below in that regard. The following authority and commentary provides a set of descriptors which can be applied to the circumstances applying to each of the applicants:
"11) In Manuel v Pasminco Cockle Creek Smelter Pty Ltd (1998) 83 IR 135 the employer argued that the selection criteria did not include a consideration of `conduct or performance' of a kind that could be put as an allegation to each of the applicants. This was despite having previously provided particulars to the representatives to the representatives of the applicants. The Pasminco particulars have a glaring analogy with the present employer's `Outline of Submissions by Pacific Coal Pty Limited' dated 3 February 1999 (ex PC21). It was held by von Doussa J:
`In answer to a request for particulars of the Selection Criteria used, solicitors for Pasminco in a letter dated 11 November said:
`The factors and characteristics which the managers took into account in deciding who to select for the available positions were the individual skills possessed, skills applied, knowledge and expertise, experience, observed work traits and flexibility, and, in some instances and to some degree, observed overall performance'.
In my opinion this selection process necessarily involved, as a matter of fact, taking into account the past performance of each of the applicant that could be brought to the attention of the applicants, in the form of allegations, which they very probably would want to answer.'. . . . . ".
[171] Interestingly, the following, which also contains an attribution to von Doussa J seems to me to accurately depict the methodology used by Pacific Coal in its application of the PA's and the accompanying PER system:
"... 12) von Doussa J also said that `capacity' is apt to describe a future capability and the past conduct or performance of the employees is necessarily considered as an indicator of likely future performance. It was a comparison made which involved, to an extent at least, past conduct and performance.
13) In the present cases, the same judicial logic confirms that the so-called `future capability' of an applicant when being assessed for the `Future Requirements' at BA meant the employer used past conduct and performance. This necessarily included past conduct and performance in the PERs as shown by the following:
a) The employer when trying to explain why an applicant like Mr Kelly received particular scores for `Future Requirements' in its submissions proceeded to refer to allegations of past conduct or performance and even comes the full circle where it said `Clearly the Applicant's previous conduct and his poor performance in relation to the criteria (Future Requirement of `Team Leadership and Membership') allowed the respondent to reach the fair and reasonable conclusion ...'.
b) The employer's admissions in respect of the use of the PERs for `Future Requirements' and/or the inconsistencies between the scores for these criteria and the employer's own internal documents is dealt with in more detail below.
14) Thus, the employer's submission that the applicants did `not put ... that there is any connection whatever between the 4 future requirements and the PER system, nor could any such suggestion ever be made out' is misconceived. It flies in the face of both previous judicial logic in this well trodden path of selective forced redundancies, and the proven facts at BA for its selection systems.
15) Returning to the employer's `Outline of Submissions by Pacific Coal Pty Limited' dated 3 February 1999 for a moment, it follows in the present cases that the AIRC is entitled to and should rely upon this Outline to find the selection for retrenchment process necessarily involved the PERs. This finding is undeniably supported by the most cursory examination of the employer's statements served and filed at the same time as the employer's Outline. A 'fair go all round' is required in the conduct of the hearing, although the employer in its year 2000 contentions has continually abandoned any real recognition or understanding of this statutory requirement.
16) Moreover, the employer either did not read or chose to ignore (because the evidence is unanswerable) the multiple admissions found in the oral evidence and documents its own witnesses as summarised in the applicants' submissions, namely:
a) The evidence set out in the Applicants' Introduction (para 11 at pp 7-10) and
b) The evidence proving the unreliability of where Mr Bates denied the pivotal part of the PERs even though he was not involved in the PERs and the G block meetings where the scores out of 40 were allocated (para 4 b) iii) F29 . . . . . ".
[172] The allegations made on behalf of the applicants as to inconsistent and inaccurate individual ratings are exemplified, in my view, by the following:
"TRANSLATION OF PER SCORES AT G BLOCK MEETING
17) In the employer's `Introduction to submissions for each individual Applicant' and under the heading `The alleged translation ...' (p 5 ) the employer tries to downplay Mr Keag's two `versions' as being narrow and technical. Accordingly, the answers Mr Keag gave initially in answer to the Commissioner's questions confirm that the witness later changed his evidence upon his realisation of the unsustainable position he had set out for the employer. Even Mr Keag's second version shows that the PERs were the substantial and operative reasons for the `Past Performance' requirements:
18) In any event, Mr Prebble accepted that the first version of Mr Keag was in general terms true, but there were said to have been some specific (unrecalled) examples where that was not the case.
19) Furthermore, in an attempt to defend the G-block meeting for the Production MRU on 22 June 1998, Mr Yeates said:
a) As seen above, in annexure A1 to his first statement his early July 1997 `Records of Discussion' records `Explained the historical performance criteria was the same as the PERs except the score range was 1 to 5, not 1 to 3. Explained the judgment was made based upon the last 18 months - 2 years (last 3 PERs) and any applicable records of behaviour before this period'. (emphasis added)
b) For Mr Cusack `We went through each of his PER's and discussed how they were used in the final scoring system for retrenchment' (annexure A1 to his first statement) (emphasis added).
c) `Future capability assessment was made against matrix criteria in the future requirements. The superintendents and I used previous behaviours and performance plus the rate of change in behaviour and performance over the last 18 months or so as input to our decision' (para 175 pp 23-24 first statement) (emphasis added).
20) As will be seen below, the consistent evidence is that the so-called selection scores for the scores for the 8 criteria were `massaged' by Messrs Yeates, Keag and Thompson (and also it seems Mr Prebble) to what they believed to be right. However all of these employer witnesses admitted that they had limited exposure to employees on shift and would not be in a position to complete PERs. It follows the capability assessments or the 8 criteria, including the `Future Requirements' were made by Manager Yeates, Superintendent Thompson and Superintendent Keag based on the following:
a) Undeniably it included the employer's perception concerning previous so-called behaviours and performance as grounded in the three PERs including the scores.
b) In the case of some applicants, it included some previous so-called behaviours and performance outside the periods of the three PERs, but Mr Yeates in what he told the applicants in early July 1997 had already qualified this to where there was `any applicable records of behaviour before this period'. The employer's statements contain some previous (or past) so-called behaviours and performance outside the periods of the three PERs, for example, the allegation of slow driving made by the employer against Messrs Appleton and Finger in the early 1990's.
c) The alleged rate of change in so-called behaviour and performance over the three PERs (ie the last 18 months). Thus, the employer's scores for the `Future Requirements' necessarily considered the past performance or conduct of an applicant in the three PERs as an indicator of the applicant's future capability or capacity.
21) The cold hard objective facts provide compelling proof of how the employer's systems operated unfairly on CFMEU award employees and were subject to bias and/or were manipulated by the company in contravention of the test propounded by the AIRC Full Bench in CFMEU and AFMEPKIU v Curragh Queensland Mining Limited Print R8490 at para 79. Those facts include for example,
a) The `black list still to go'. Has there ever been a previous industrial case where the applicants have been able to prove that the employer used such an expression in selecting individuals for termination.
b) The 21 October 1997 communication evidenced by Mr Riordan's records, and the changing of the meaning to an opposite. . . . .".
[173] The opportunity for removal from the black list was limited, as the following in part extract from the submissions on behalf of the applicants reveals:
"c) Only 2 employees got off the `black list still to go' or off the `Black list re Retrenchment Process', namely Mr Cec Mooney (coal plant) on 3 February 1998 and Mr Frank Scott (driller in Mine Services) no later than 14 April 1998. See the Chronology in F4 and the `Pool of alleged 'Performance improved'` in F5 pp 35-38. Nine of the applicants were from Overburden and Supervisor Campbell admitted that nobody got off the list to be retained. . . . .".
[174] In terms of the opportunity for an applicant by way of individual performance to respond to the PA's and PER process requirements of Pacific Coal, what follows hereunder by way of the following extract from the applicants' Year 2000 submissions, is indicative of the lack of opportunity provided to an applicant to actually do this, revealing in my view, a manipulation of the process where the applicants were concerned:
". . . d) Sending most of the applicants to the Mine Services chain gang or, putting it a different way, to King Browne's `snake pit'. Mr Barnes summarised the position ` ... most of us had meaningless jobs for a fair bit of it (PER3) so if it wasn't a joke what chance did we have to improve?' (FRX917 L8).
e) The ticks and crosses on the 1997 and 1998 Guidelines documents show that the ratings given to certain applicants were never justified as applicants did, in fact, meet the unilaterally introduced employer expectations. Why did the applicants still receive 1 for a PER criteria?
f) Mr Crooks candidly admitted the overlap and multiple use by the employer of conduct and performance allegations and criticisms from the PERs by the employer in the `Past Performance' requirements and the `Previous Performance' requirements for Messrs McGuiness and Walsh. See also the capability assessment forms of Mr Riordan in General Attachments 26 and 27 in ex PC8. Thus, the employer's refrains, such as `It is not suggested by the Applicants that there is any connection whatsoever between the four future requirements and the PER system ...' and `There is no cross-examination of any employer witness which would cast doubt upon the accuracy of the scores attributed to the Applicant for the four future requirement criteria ...' (see, for example, Mr McGuiness p 7.6) does not even warrant the explanation of being a blinkered approach by the employer. Rather, it is an employer submission made in blind ignorance of the evidence in the present proceedings, including the cross-examination of Supervisor Crooks and the content of the employer's own rating documents, and demonstrates that the employer still persists on calling black as white".
[175] The issue of the "black list still to go" permeates, in my view the whole of the PER process used to the extent that it hangs like an albatross around the neck of Pacific Coal. By way of clarification, I am of the view that such is elevated to the status of being a central plank in the submissions of the applicants given that this list, from November 1997, contained the names of the applicants through the whole of the PER process referred to. Notwithstanding the fact that there were obviously other employees upon this list who were able to, in one way or another get themselves removed from such list (see above in paragraph 172), this list was ultimately relied upon to formalise the selection of the only employees remaining upon such list, namely the applicants, for termination in July 1998.
[176] The following extract depicting the evidence of Garry Barnes is an example of the way Pacific Coal went about demeaning the applicants and denying them opportunities to perform work which would have provided an opportunity to have improved their standing insofar as their rating was concerned:
"a) Transferred to mine services in early 1998
33) Mr Barnes and in particular where Ms Arnold accepted (XX2817) that it sounded like a situational constraint:
a) In the mine services the employees were allocated menial tasks such as chipping weeds with a hoe rather than using a weedicide as was normally the practice at BA and painting tyres with a broom as opposed to spray painting which was the normal practice at BA: Mr Barnes ex CFMEU50 para 40. Mr Barnes was never allocated to work which recognised his skill level: paras 42, 54.
b) Q Do you therefore find it unusual that you weren't called in because they were trying to make it work with the current structure?---I find it unusual considering that the letter that was supposed to have been sent to us from Mr Bates that we're going to be given every chance to improve our standing and what we were doing and yet then we weren't allowed to be used even for one day as a relief to do work and for a new structure and to be more efficient. It seemed very strange to me that many days there'd be a dragline operator missing and there was four or five dragline operators on site chipping weeds or whatever and they couldn't be used. You'd rather - the company would rather pay overtime: XX845 L16.
c) Q Did you believe it (the letter of Mr Bates dated 12 March 1998) really over-rode what had been told to you by Mr Prebble?---I Think it was a joke.
Why do you say that?---Because we were picked to go in November and even if this letter and his comments were right, why were we given jobs that after we were told how we performed in the last term would be very important and yet all - most of us had meaningless jobs for a fair bit of it so if it wasn't a joke what chance did we have to improve?: FRX914 L4".
and this was depicted within the applicants' submissions as something akin to a joke by reference to the following:
"....d) Sending most of the applicants to the Mine Services chain gang or, putting it a different way, to King Browne's `snake pit'. Mr Barnes summarised the position ` .. most of us had meaningless jobs for a fair bit of it (PER3) so if it wasn't a joke what chance did we have to improve?' (FRX917 L8).".
[177] The authorities which have bearing upon this matter were raised by both parties and put in issue, firstly by the applicants, by way of the following:
"49) The employer submits that ASC (No. 2) at 372 is, amongst others, an authority for the proposition `There are decisions on point from Australian industrial tribunals which deal with and approve the use of subjective performance criteria in a redundancy situation'. The Full Court of the Federal Court made no such statement when p 372 is read. It held `It is for the employer to choose the basis for selection for redundancy from the pool of eligible employees. It is only if the employer chooses by reference to conduct or performance criteria that s 170DC will apply' (372.3). The Full Court went on to find that the employer had not attempted to discharge the onus under s 170DE(1) of establishing that there was a valid reason for the selection of each appellant. The employer made the decisions concerning the selection of each particular appellant, and determined the basis on which the selection was to be made. The employer should justify those decisions. The employer was found to have contravened s 170DC and also 170DE(1) (where the statutory onus was then on the employer). (My emphasis).
50) In the Reply on No Procedural Fairness or Due Process, the Full Court's approach on performance and conduct characteristics is set out in more detail.
51) The company in that case had an enterprise bargaining agreement which provided that the ASC will determine which employees are to be made redundant (ASC (No. 1) at 110.4). In the present cases, the seniority clause incorporated in the applicants' contracts of employment and the clause 20 award are to the opposite effect".
[178] As far as the actions of Pacific Coal in allegedly favouring one set of employees over another (those who had signed AWA's as opposed to the applicants), the following construction is placed on this by the submissions of the applicants:
"52) In ASC (No. 1) at 117.8 it was reasoned that the welders were not equal in relation to submarine hulls. The work was intricate and difficult. Much of it was performed in cramped and uncongenial conditions. Although all welders in the hull shop had acceptable trade qualifications, some handled these challenges better. However, in the present cases, as seen in the applicants' primary submissions `4 Employer Preference to AWA Employees Over CFMEU Award Employees' (F5 para 28 e) pp 16-17), former staff employees, previously employed in areas such as first aid, town services and store jobs, were transferred into Mr Keag's Pit Operations in early 1998 on AWAs where they had been selected by the employer to be kept at BA. Only Malcolm Pidgeon had any operating skills and yet all these staff employees still received straight 8' including 2 for Skills. No objective analysis can support a submission that these staff employees could contribute in terms of skills, experience and efficiency at anything like the level of the applicants with between 8 and in excess of 18 years production experience.
53) The ASC did not purport to use PAs as part of the selection process and did not use anything like the `black' list to make offers of voluntary redundancies (ex CFMEU111 at p 503)".
[179] The applicants further attacked the application of the PER system as set out hereunder:
"54) Further, the ASC did not have anything like Mr Keag's memorandum dated 21 July 1997 setting out the employer's own methodology where undeniably a material consideration in the AIRC's determination in deciding if the employer's method of assessment in its selection systems operated unfairly is ` ... the PER system methodology set out in Ex Comalco 64. ...' (Weipa case (1996) 63 IR 138 at 168.5. `Common Pitfalls In Doing A PER' or other words common pitfalls in BA's method of assessments, as set out in the employer's own methodology, include:
a) `There should be no surprises for the employees ...'
b) `Having inconsistent standards for different employees, and across different work groups'
c) `Not being specific enough about performance issues.'
d) `Failure to have documented evidence of performance discussions.'
55) In other words, the unfair operation of the employer's systems is shown by its failure to avoid the pitfalls acknowledged in its own methodology. It should be noted that these pitfalls were set out in the secret document of Mr Keag which was only disclosed by the employer in 1999 when serving the General Attachments folder now marked ex PC8. P & E employees, unlike Supervisors and above at BA, were never given this type of information and instruction to help them understand and/or challenge the employer' systems. The employer now suggests that reasons justifying the termination of applicants include where an applicant did not ask a Supervisor how to improve performance from PERs or was not forward in requesting assistance (see, for example, Mr Appleton pp 23-13). The employer is putting the cart before the horse, if one accepts the obligations of the employer set out in the employer's own methodology and this is particularly the case where the P & E workforce were not even told what was in the employer's PER cart". (My emphasis).
[180] To summarise my conclusions, I conclude that the PA's and its supporting PER process, whilst a system open to application by Pacific Coal at its Blair Athol mine, upon my considerations of the system and process and its application, have failed to satisfy me that the applicants or anyone else for that matter, could feel comfortable with or be satisfied with in losing their employment by way of its application to them, for the following reasons:
[181] There was no procedural fairness or due process extended to the applicants and such PA's and PER process operated unfairly for the applicants whereby each was subjected to bias caused by the manipulation by Pacific Coal through those responsible for its administration (see CFMEU v Curragh Queensland Mining Limited [Print R 8490]), aided by the description of flaws and inconsistencies in the Pacific Coal systems as set out hereunder drawn from the applicants' Year 2000 submissions:
"a) Inadequate employer training for assessors.
b) Inconsistent employer treatment of the dot points on the PER form appearing below each of the four criteria.
c) Inconsistent use of the preparation form for PER1.
d) Inconsistent use by the employer of its `Guideline' documents for PER2 and 3.
e) Employer comments do not justify particular ratings in PERs.
f) Inconsistent application of the alleged automatic 1 rating.
g) Arbitrary and capricious use of reported safety matters
h) Dredging up matters from the past outside the PER review period.
i) Most of what occurs to us (including at work) is not contained reliably in memory.
j) Inconsistent application of the 3 PER's to rate on `Past Performance' requirements in the so-called selection process;".
[182] This is an appropriate description of the application of such to the applicants and is, in my view, supported by the numerous references as to the construction of the evidence of Pacific Coal witnesses made on behalf of the applicants, to the extent that such supports the above description attached to it.
[183] It is open to conclude, following an examination of the evidence of the applicants as opposed to that of the Pacific Coal witnesses, that the Pacific Coal witnesses, involved in the application and implementation of the PA's and PER system, were of a mind that they would never be held accountable for their actions in terms of their treatment of the applicants and that their performance, under cross-examination which was vigorous and searching but no more than that, revealed this.
[184] This led to the giving of evidence by some of such witnesses of a nature which was not capable of defending the individual actions by some of such persons, when it is considered that they were supposedly trained to administer and apply the PA's and PER system, whilst the applicants essentially had no training or assistance from their raters, which worked to their individual detriment.
[185] In contrast to this the applicants gave consistent evidence which could reasonably be expected of witnesses who were, to a large degree, in the dark about allegations made about them and their work performance. The applicants cannot be held to have given inconsistent or misleading evidence, given the failure of the persons responsible for the administration of the PER process to appropriately bring matters upon which they intended to rely, to the attention of the applicants.
[186] As to the evidence of Ms Hoch, I accept that this witness was truthful. In fact, the evidence this witness disclosed has been borne out and is evidence which I prefer when an examination of the evidence which flowed from Pacific Coal witnesses, who attempted to put in issue Ms Hoch`s evidence, is considered.
[187] In regard to the valid reason question and authority upon this, and accepting that whilst this question of itself is determinative of applications under section 170CE, which claim that the individual's termination of employment was harsh, unjust or unreasonable, I note the following extract from the applicants' Year 2000 submissions:
"a) In Selachandran v Peteron Plastics Pty Ltd (1995) 62 IR 371 at 373 Northrop J said the adjective "valid" should be given the meaning of sound, defensible or well founded. A reason which is capricious, fanciful, spiteful or prejudiced could never be a valid reason. At the same time the reason must be valid in the context of the employee's capacity or conduct or based upon the operational requirements of the employer's business. The provisions must be applied in a practical, commonsense way to ensure that the employer and employee are each treated fairly.
b) To the extent the employer pleads managerial prerogative, the test applied for many years by the Commission is for the Commission to examine all the facts and not to interfere with the right of the employer to manage its own business unless it is seeking from employees something which is unjust or unreasonable: XPT case (1984) 295 CAR 188 at 191.
c) Additionally, there exists separately the injunction of a "fair go all round" in the WR Act's termination provisions, as dealt with in Mollinger, and as seen above this is not limited to the manner in which the hearing is conducted or the consideration of the remedy to be rewarded but extends to the Commission's consideration of all of the relevant circumstances.".
Findings
[188] In having reached the above conclusions I now turn to the findings which I believe, based upon the evidence and the submissions and the numerous authorities raised by the parties, are reasonably open to me:
(A) I find that the PER system implemented by Pacific Coal in itself was a system open to Pacific Coal to implement for the purpose of improving and measuring performance, and improving production at the Blair Athol mine which led to a downsizing of its workforce under the "operational requirements" banner and authority for this is reasonably open, based upon the following:
". . . . The term operational requirements has been given a broad interpretation by the Courts. In Nettlefold v Kym Smoker Pty Ltd (1996) 69 IR 370 Lee J held at 373 that the phrase `operational requirements' is:
`... a broad term that permits consideration of many matters including past and present performance of the undertaking, the state of the market in which it operates, steps that may be taken to improve the efficiency of the undertaking by installing new processes, equipment or skills, or by arranging for labour to be used more productively, and the application of good management to the undertaking'
This approach has been affirmed in Shorten v Australian Meat Holdings Pty Ltd (1996) 70 IR 360 and has been held to be expressly applicable to section 170CG(3)(a): Fetz v Qantas Airways Limited (Print P6706, per Ross VP, 17 November 1997); Liu v Coms 21 Limited (Print R9249, per Lawson C, 27 September 1999). . . .".
(B) I find that the system was also capable of use as an associated tool for the purpose of restructuring the business at its Blair Athol mine, to select from its workforce those individuals it wanted to retain, subject to the proper application by and of those responsible for the administration of such PER system, an approach which it seems to me would not offend what the Full Court of the Industrial Relations Court said in Kenefick v Australian Submarine Corporation (No. 2) (1996) 65 IR 366 at 372, subject to it being fair, consistent with the following authority:
"The adoption of the selection criteria to select employees for redundancy from a pool of eligible employees is a matter within the discretion of the employer subject to it being fair: see Full Court of Industrial Relations Court of Australia Kenefick v Australian Submarine Corporation (No 2) (1996) 65 IR 366 at 372; per Farrell JR Craig v West Australian Petroleum Limited (1997) 76 FCR 419. Provided that the employer's method of selection is based on fair and reasonable criteria the court should not interfere with its decision even though other reasonable approaches could have been adopted which would have preserved the applicant's employment: per Patch JR Pritchard v Standard Chartered Bank of Australia (1996) 64 IR 315 at 318". (My emphasis).
(C) However I also find that in order for the PER system to be fair it needed to be properly understood by all who would be subject to it and that this required that appropriate training of all persons in the system was necessary. To that extent whilst some training within the system was provided to certain management and supervisory staff and some of the workforce, there was a failure by Pacific Coal to appropriately train all of the supervisory staff and the entire workforce. This failure was detrimental to the applicants not trained at the time of the system's implementation and that the evidence in these proceedings reveals that Pacific Coal failed, among other things, the following tests:
"a) `There should be no surprises for the employees ...'
b) `Having inconsistent standards for different employees, and across different work groups'
c) `Not being specific enough about performance issues.'
d) `Failure to have documented evidence of performance discussions'."
(D) In particular, I find that the applicants suffered prejudice and detriment as a result of their lack of understanding and/or training in relation to the PER system and the manner in which it would affect their employment. As a consequence, this prejudice and detriment continued to affect the applicants up until the time of the termination of their employment.
(E) Accordingly, I find that the termination of the employment of the applicants, in view of Pacific Coal's failure to properly and fairly administer, educate and enforce the PER system in respect of the applicants, was unreasonable to the degree that such offends what was held in Kenefick v Australian Submarine Corporation (No. 2) (1996) 65 IR 366 referred to in sub-paragraph 188(B) above, to the extent that the application of the selection criteria was not fair.
(F) Further I find that such detriment was twofold in that there was an inappropriate application of the system. This inappropriate application was caused by a lack of discipline amongst those supervisors responsible for one on one interviews with employees in their areas as to the method of rating of such individual employees. This was compounded by a failure by the superiors of the raters to apply the necessary discipline to those responsible for such one on one interviews and ratings. This in turn led to a denial of natural justice to the detriment of the applicants, in particular, brought about by this lack of discipline which was essentially sanctioned by their superiors and that this was unjust and unreasonable.
(G) I find that the denial of natural justice afforded to the applicants was, in my view, initially underpinned and ultimately compounded by the inclusion of the names of all of the applicants upon a list described as a black list. This list was derived as a result of the outcome of a collective meeting of supervisors who were imbued with the authority to identify based upon a "gut feeling" the so-called 50 worst performers at the mine.
(H) I find that the applicants, when regard is had to section 170CG(3)(b) of the Act were not informed in a manner necessary about the existence of such black list or of the reasons for their inclusion upon this list, inconsistent with the requirements of such subsection which states:
"(b) whether the employee was notified of that reason;".
This lack of notification by Pacific Coal to the applicants as to the real reason for their selection for termination by way of redundancy was never revealed to the applicants and I find that such was unjust.
(I) From an assessment of all of the evidence, I find that the impact of the existence and non-revelation of the black list and its continued application during the period leading up to and including the date of the termination of each of the applicants' employment, coloured (so to speak), the thinking of the individuals administering such list. I find that this led to a continuing desire (or agenda) of the individuals responsible but acting on behalf of Pacific Coal, to ensure the initial selection process in respect of the black list was maintained.
In reality, such view prevailed to the extent that the method of seeing the removal of an employee from such black list, and there were only two employees removed, was not always for reasons related to improved or enhanced performance.
The evidence reveals that this was achievable with the acceptance of matters which have been described as non-contextual.
In that sense non-contextual matters and their application to the applicants should not and could not play a role in a performance based selection within a genuine performance appraisal scenario to the extent that such selection could be described as properly constituted or fair. The implications of this were that the termination of the employment of each of the applicants was unjust and unreasonable.
(J) I find that the applicants, by way of their early identification upon the black list which at some point in time became further enhanced by the term "still to go", were targeted and singled out for termination from the very commencement of the process.
The recall of alleged matters from, in some instances the early 1990's, appropriately described as "dredging" for some of the applicants, was in my view, an attempt by those responsible at Pacific Coal to justify in an ongoing manner, the singling out of the applicants and that this practice was unjust and that such is capable of being described as the denial of a fair go all round and comes within the following description as follows in Byrne in that there is an overlap of the description of harsh, unjust and unreasonable which attaches to the termination of each applicant:
"b) It may be that the termination is harsh but not unjust or unreasonable, unjust but not harsh or unreasonable, or unreasonable but not harsh or unjust. In many cases the concepts will overlap: Byrne v Australian Airlines (1995) 185 CLR 410 at 465.5.
c) The expression `fair go all round' means it is not wrong to conclude that whether there was a fair go all round in the circumstances was a factor to be taken into account in determining whether the termination was harsh, unjust or unreasonable. `There is little doubt that s 170CA(2) enjoins the Commission to apply basic notions of fairness in carrying out its functions under Division 3. The injunction is not limited to the manner in which the hearing is conducted or the consideration of the remedy to be rewarded but extends to the Commission's consideration of all of the relevant circumstances. Were it otherwise the reference to Loty and Holloway would not make sense.': Full Bench of the AIRC (Giudice P, Polites SDP and Gregor C) in National Jet Systems Pty Ltd v Mollinger Print R3130 at paras 10-13.".
(K) I find that there was an apparent history wherein the Pacific Coal management team had been at odds with the Blair Athol CFMEU Lodge and its members for years. I also find that certain members comprising such management team were suddenly presented with an opportunity to put the CFMEU Lodge and some of its member in what, some if not all, of the management team felt was their proper place. This reflects an unreasonable intent in terms of the applicants' ultimate terminations which in turn led to a conspiratorial allegiance amongst those responsible for the ratings given to each of the applicants through the application of the PER system.
(L) I find that this conspiratorial allegiance existed by way of a shared knowledge amongst the supervisors and upper and senior levels of management within Pacific Coal at Blair Athol mine to the extent that the applicants could be given a "hard time" without rebuke from upper management. This involved a strategy designed to force the applicants to accept the redundancy package and various methods were used to achieve this, such as:
"d) Sending most of the applicants to the Mine Services chain gang or, putting it a different way, to King Browne's `snake pit'. Mr Barnes summarised the position ` ... most of us had meaningless jobs for a fair bit of it (PER3) so if it wasn't a joke what chance did we have to improve?' (FRX917 L8).
e) The ticks and crosses on the 1997 and 1998 Guidelines documents show that the ratings given to certain applicants were never justified as applicants did, in fact, meet the unilaterally introduced employer expectations. Why did the applicants still receive 1 for a PER criteria?"
I find that this was representative of harsh treatment of each of the applicants and contributed to the resulting termination of employment of each of the applicants, which I find was unjust.
(M) I find that based upon my observations of the evidence relating to the actions of Mr Scott Browne towards those applicants who came under his purview, that such could be likened to "blood sport" for Mr Browne and the term "King Browne's snake pit" used to characterise the culture of the work area under his control into which some of the applicants were placed during the PER reviews, is indicative of this.
Mr Browne's success in, as he put it, diminishing the authority of the CFMEU at the Blair Athol mine was used by him in a CV he prepared for a position that he was applying for which is detailed within a confidential exhibit entitled Exhibit Pacific Coal 113.
I find Mr Browne's attitude and behaviour towards the CFMEU membership at Blair Athol mine as being indicative of a person, (bearing in mind that he was responsible for rating certain of the applicants in the area under his jurisdiction), lacking not only the necessary personal evenhandedness to fairly rate such applicants but also an inability to properly rate employees caused by a lack of appropriate training in that regard.
Further, the ratings could only be viewed as susceptible to inaccuracy and prejudice and therefore cumulatively improper, thus ensuring that such applicants were selected for termination. Such an outcome, in my view, is not one representative of a fair go all round and is of a harsh, unjust and unreasonable nature to the extent that such overlap (see Byrne).
(N) I find that the evidence of the two expert witnesses in performance systems, Ms Knox and Ms Arnold, called in the first instance, by the applicants and in the second instance by Pacific Coal, concurred upon many issues to the extent when the Blair Athol PER system is set against what is the acknowledged content model of a fair performance system, that the termination of each applicant was individually harsh. This finding is confirmed by way of the following extracts from the applicants' submissions and goes to serve and highlight the discrepancies and weaknesses in the Blair Athol PER model in that the following reference to an authority on this subject drawn from the applicants' Year 2000 submissions is an accurate reflection of what should have occurred but however, did not:
"`Consultation between employers and employees, preceded by the distribution of adequate information is not only sensible but essential if commerce and industry are to meet the challenge of progress in a spirit of harmony and with some regard human dignity': FCU v Victorian Employers' Federation (1984) 154 CLR 472 at 511 (Wilson J) (emphasis added) and referred to with approval when dealing with applications that redundancies were harsh, unjust or unreasonable in cases such as Quality Bakers of Australia Ltd v Goulding (1995) 60 IR 327 at 334.8 (Beazley J) and Mitchell-Collins v The Latrobe Council (1995) 60 IR 408 at 490.7 (Spender J)"..
The CFMEU submissions referred to the first report (Exhibit CFMEU 55) of Ms Knox suggesting that she said appositely at page 4 of such report:
"One way of estimating fairness is to ask whether the performance appraisal system is structured in such a fashion that all employees would have been assessed in a consistent fashion. One way of assessing potential for consistency is to ask whether a performance appraisal system is sufficiently structured so as to eliminate the possibility of variation amongst assessors'.
`a) The applicants in the performance effectiveness review (PER) process were not accorded procedural fairness or due process. Ms Arnold, the employer's expert, admitted it is accepted that you can't have a fair performance appraisal (PA) system without both due process and accuracy. This is not an elusive distinction - it is just the accepted convention: XX2713. After conceding she did not know factually what was the position at BA (based on what she was briefed with by the employer for preparing her report), Ms Arnold in cross examination was then asked questions based on actual evidence adduced from the employers' witnesses, and she admitted such evidence meant in terms of due process for a PA that the Blair Athol position was grossly unfair and/or fundamentally unfair. . . . . '.".
(O) I find that based upon the above, that the Blair Athol Performance Appraisal System was lacking in application by those responsible for the appropriate concept of consultation between Pacific Coal and all of its employees. This, I find, created a lack of fairness in the sense that there was a bias which led to inconsistency in rating employees unless they fell into a certain mould. That certain mould, I am satisfied, represented among other things, being a non CFMEU member and/or a signatory to an AWA. Another criteria to fit the mould required included the open acceptance at Blair Athol mine by an employee of Pacific Coal agreeing to the use of contractors to the potential detriment of what the applicants perceived as being the job security of the permanent workforce.
Or alternatively, turning a blind eye to collective agreement rights by giving up rights such as quarantined skills. These criteria appeared to have been inherent in the ultimate rating received by each applicant to their detriment and did not reflect a fair go all round.
(P) I find that appropriate steps were not taken by Pacific Coal designed to eliminate the possibility of variation amongst assessors. This, I have concluded was deliberate because what became a bias was a shared bias amongst those capable of redressing such bias. Accordingly, when applied to the applicants, the appraisal failed the due process and accuracy test essential for a Performance Appraisal System and as a result was not capable of scrutiny if challenged. The outcome for the applicants was unjust and unreasonable by way of overlap (see Byrne).
(Q) As far as each individual applicant is concerned, it seems to me that upon an examination of the above conclusions and findings and consistent with my obligations to have regard to subsection 170CG(3) of the Act and its application to the circumstances reveals, when set against such subsection of the Act, the following:
· In having regard to subsection 170CG(3)(a):
"(a) whether a there was a valid reason for the termination related to the capacity or conduct of the employee or to the operational requirements of the employers undertaking, establishment or service;".
I find that the termination of each of the applicants was not representative of a fair go all round in that their individual terminations were related to the capacity and conduct of each individual applicant in such a way that the normality of that status was not in evidence before this Commission. This finding is founded upon the fact that each of the applicants remained members of the CFMEU, were not signatories to an AWA, and had not agreed to give up collective agreement rights.
· I find that the applicants did not necessarily subscribe to Pacific Coal theories as to use of contractors nor agree with the actions of Pacific Coal in pressing for acceptance of AWA's across the site. However I have formed the view that this lack of subscription to the wants of Pacific Coal was by no act other than expressing a different point of view about those issues or not participating by taking up an AWA and that this was to the individual detriment of each of the applicants and was harsh, unjust and unreasonable by way of overlap (see Byrne).
· I find that the termination of each applicant was associated with conduct and capacity and in having regard to subsection 170CG(3)(b):
"(b) whether the employee was notified of that reason; and".
the applicants were never notified of the true reason for their termination. The so-called justification for the termination of each of the applicant's employment was by way of selection based upon ratings emanating from the PER system which was flawed and misapplied and that this was unjust.
· In this regard I find that the PER system at best, when the application of it is considered, reveals a flawed process by which the applicants were never intended to be given an equal opportunity with other employees as to fair ratings and that this had as one of its foundations, the choice of not attending the first PER, given that such was voluntary. I also find that such flawed process was designed to ensure that the applicants would remain on the "black list still to go" and that this represents an unjust and unreasonable termination in the case of each applicant.
· In having regard to subsection 170CG(3)(c) as to:
"whether the employee was given an opportunity to respond to any reason related to the capacity or conduct of the employee",
· I find that based upon the evidence arising from the PER interviews, reasons relating to capacity or conduct were either not recorded or made known to each of the applicants by those persons responsible for this in a manner that would have afforded each of the applicants an opportunity to respond.
If such an opportunity had have been provided to each of the applicants then such applicant could have put his side of the story to either corroborate such claims as factually accurate allegations or raise his version in rebuttal to the extent that a true consideration of the rating and any adjustment could properly be made. Accordingly I find that this failure by the person conducting the interview/s is reflective of an unjust termination and that such finding is supported by the following authority:
". . . . . As seen below, by analogy, the AIRC has found that a proper opportunity to respond means giving an employee the specific and substantive reasons, rather than an opportunity using a general appellation or one clouded in generality - see, for example, Fischer v Telstra Corporation Limited Print R2558 (1 March 1999) (Ross VP, Duncan DP, Redmond), G McKenzie v Imperamada Pty Ltd Print S0628 (Jones C) (3 November 1999) and Swain v Ramsey Food Packaging Pty Ltd Print S2209 (Jones C) (24 December 1999)".
· I find that the lack of training combined with a lack of satisfactory explanation provided to each of the applicants concerning the PER system, basically left each applicant vulnerable to biased and improper selection for redundancy. I have formed the view that this bias was intended to ensure that the remaining workforce would be compliant and that the treatment of the applicants was designed to be a salutary lesson for the benefit of the remaining employees (see the evidence of Mr Riordan at Transcript page 411, xx 3705-3706 quoted from the CFMEU's submissions):
"d) Mr Riordan:
(i) He wrote "People going to First Aid raising issues but too scared to tell SUPV (PERs)": ex CFMEU111 at p 411, XX3705 - 3706".
· As an example of the perception amongst the workforce as to how the biased and improper application of such system was perceived amongst the continuing workforce, the following extract from the CFMEU's submissions is instructive:
"(ii) Narelle Tamblyn as the Human Resources Officer at BA interviewed AWA employees to see what they thought about the PER system and the results were reported on at a managers' meeting: XX3707 - 3711, the new managers' minutes, ex CFMEU111. The report back included "Wide perception that PER scores reflect the personal relationship between the employee and his supervisor, regardless of their work ability."
· In order for the bias to have been successful it was required that the PER system be manipulated and was capable of manipulation to ensure that each and every applicant would fail and that such failure was ensured. I find, having regard to subsection 170CG(3), that this failure was caused by those responsible for the application of the PER system in that the applicants were denied a fair go all round when compared with the treatment of other employees at the Blair Athol mine.
· Insofar as subsection 170CG(3)(e) is concerned as to "any other matters that the Commission considers relevant" and in having had regard to this, I find that there was a conspiracy in the form of knowledge not revealed applied by Pacific Coal attached to the use of coloured lists used to distinguish those employees that it intended to keep (the Blue List) and those it intended to terminate (the Black List).
· I find that it cannot seriously be submitted by Pacific Coal that the use of such coloured lists to identify employees as revealed above was something that was not known to it at the time the various applications by way of Summonses were made on behalf of the applicants for the production of relevant documents, long before the evidence of Ms Hoch revealed the existence of such lists and that Pacific Coal attempted to keep this secret.
(R) I find that the attempt by Pacific Coal to deflect attention from the PER system and its use as to the selection of the applicants for redundancy hereunder described as "Another Employer Recant" earlier by the CFMEU as follows:
"a) `It is the retrenchment process and Exhibit PC74 which the Commission should focus its attention upon in deciding the matter. It is not the PER system, for that was not the system which was used to select employees for forced redundancy' (pp 6-7).
b) ` ... This case is not about the PER system. The fact that so many days of evidence were devoted to a close examination of the PER system was because the Applicants, it is submitted erroneously, decided to conduct their cases this way. Exhibit CFMEU74 was prepared having regard to 8 criteria. Only 4 of those criteria reflect the criteria in the PER system' (6.3 p 25). The two emphasised parts of the employer's recent contentions contradict each other and belie the tangled web within which the employer has caught itself as it struggles to come to grips with its inability to put the smashed pieces of its systems together again.
c) `In any event the PER system is not on trial here, for it was system designed to promote improved performance. The Commission must focus on the appeal process to the General Manager, Mr Bates' (1.4 pp 29-30).
d) `The process by which the Applicants were selected is outlined above. The PER system was an entirely separate process designed to improve performance. The 'verification' of the PER scores is therefore irrelevant' (8.12.4 pp 92-3).
e) ` ... the PER system is not relevant because it did not from the basis of the forced redundancy process, which was a separate and distinct process' (9.4.3)".
is inappropriate and alternatively, it is appropriate to consider the PER system and its selection usage in reaching the above findings in this matter.
(S) I find that insofar as the question of whether the termination of the employment of each of the applicants was concerned and having regard to subsection 170CG(3) of the Act, that such terminations were harsh, unjust or unreasonable as follows:
· Having had regard to subsection 170CG(3)(a), I find that Pacific Coal failed to bring such matters to the notice of the applicants in such a way that the applicants could respond to such allegations relating to conduct or capacity.
· I find that all such alleged conduct or capacity matters were used in a cumulative manner within a PER system based upon a retrospective basis for the following reasons:
_ To apply the PER system on a prospective basis would have required appropriate training of the staff and employees at Blair Athol mine in their respective and prospective roles within the PER system. Such training would have created a level playing field by which each of the participants, including the applicants, would have been consistently rated not only in PER 1 but through the subsequent 2 and 3 processes, which was not the case for the applicants. The retrospective application of PER 1 with its "dredging" elements essentially put the applicants in a position of disadvantage. I find that this position of disadvantage was used as the ongoing basis to frame the decision to terminate the employment of each of the applicants. (See Crozier v Palazzo Corporation Pty Limited t/as Noble Park Storage and Transport [Print S5897]).
_ Having had regard to subsection 170CG(3)(c), I find that no opportunity was accorded to the applicants to put in issue this PER 1 rating, based as it was upon inaccurate allegations and or unproven allegations, and that this was used in the accumulation of scores against the applicants. In this regard the applicants were not made aware of the actions of Pacific Coal which constituted the "dredging" of matters in arriving at the PER 1 rating, given that none of the applicants attended the PER 1 interview which was voluntary.
_ I find that on balance the PER system relied upon by Pacific Coal contained inherent weaknesses which were compounded by such inappropriate application of such system to the applicants that it would be impossible to
determine whether each applicant would ever, (if treated equally to other employees), have been rated above or below others retained in their place and that the termination of the employment of the applicants did not represent a valid reason (see Selvachandran) or a fair go all round to each of the applicants.
(T) In regard to the valid reason and the fair go all round questions and authorities upon this, whilst this question of itself is not determinative of applications made under section 170CE which claim that the individual applicant's termination was harsh, unjust or unreasonable, I note the following extract from the applicants' Year 2000 submissions:
"a) In Selachandran v Peteron Plastics Pty Ltd (1995) 62 IR 371 at 373 Northrop J said the adjective "valid" should be given the meaning of sound, defensible or well founded. A reason which is capricious, fanciful, spiteful or prejudiced could never be a valid reason. At the same time the reason must be valid in the context of the employee's capacity or conduct or based upon the operational requirements of the employer's business. The provisions must be applied in a practical, commonsense way to ensure that the employer and employee are each treated fairly.
b) To the extent the employer pleads managerial prerogative, the test applied for many years by the Commission is for the Commission to examine all the facts and not to interfere with the right of the employer to manage its own business unless it is seeking from employees something which is unjust or unreasonable: XPT case (1984) 295 CAR 188 at 191.
c) Additionally, there exists separately the injunction of a "fair go all round" in the WR Act's termination provisions, as dealt with in Mollinger, and as seen above this is not limited to the manner in which the hearing is conducted or the consideration of the remedy to be rewarded but extends to the Commission's consideration of all of the relevant circumstances.".
(U) Consistent with the obligation I am required to have in relation to having regard to section 170CG(3) as to the issue of a valid reason for the termination question and, aware that the question of whether there was a valid reason for the termination, whilst not determinative, but merely one factor which I must have regard to in making the assessment of whether the termination was harsh, unjust or unreasonable I also make the following findings:
_ Having had regard to section 170CG(3) as to whether it could be said that the employer had reasonable grounds, on the facts available at the relevant time of an order which justified the termination of the employment of the applicants. In this regard, I have taken account of the following extract from the applicants' submissions as it applies to the matters before me:
"d) Two particular facets of the statutory framework are relevant.
i) The first relates to the objects of Div 3 of Pt VIA of the Act in s 170CA(1) and (2). Section 170CA(2) makes it clear it was intended that in the arbitration of a claim that a termination was harsh, unjust or unreasonable the Commission should ensure that a `fair go all round' is accorded to both the employer and employee concerned.
ii) The second relevant feature of the statutory framework is s 170CG(3). The first point in respect of s 170CG(3) is it clear from the subsection that the existence of a `valid reason' for the termination is a factor which the Commission must have regard. However, it is not the only factor to which the Commission must have regard. Unlike the position under s 170DE(10 of the former Act the question of whether there was a valid reason for the termination is not determinative but merely one factor which the Commission must have regard to in making its assessment of whether the termination was harsh, unjust or unreasonable. The second to be made about s 170CG(3) is that it does not, in terms, limit the Commission's consideration to an application as to whether the employer had reasonable grounds, on the facts at the relevant time, for terminating the applicant. Indeed the requirement in s 170CG(3)(e) to have regard to any other matters that the Commission considers relevant appears inconsistent with this limitation: Australian Meat Holdings Pty Ltd v McLauchlan (1998) 84 IR 1 at 7 - 8 (Ross VP, Polites SDP and Hoffman C)....".
_ I have considered the following part of the defence offered by Pacific Coal as to a valid reason and genuine operational reasons for the termination of the applicants expressed as:
"While the existence of valid reason is not, of itself, determinate of the question whether the termination is harsh, unjust or unreasonable, the Respondent acknowledges that `it will often be a very important factor': Windsor Smith v Liu and Others (Print Q3462, Full Bench: Giudice J, Polites SDP, Gay C at 10);.....".
and further
"The Respondent submits that the evidence set out below demonstrates that the Respondent had genuine operational reasons for undertaking the restructure which ultimately resulted in the terminations of the Applicants. Accordingly the reasons for the termination of the Applicants were valid and had the required connection with the operational requirements of the Respondent's business......".
about which I find as follows:
_ Having made findings earlier in Findings (A) and (B) of this paragraph that the process of the PA's and its supporting PER rating of employees was a method open to Pacific Coal for the selection of those that it wanted to make redundant upon operational grounds and could superficially appear to provide a valid reason for the termination of the applicants, when this however is set against whether the employer had reasonable grounds, on the facts at the relevant time for terminating the employment of the applicants, I find that such has not been made out to my satisfaction.
_ In having regard to subsection 170CG(3)(a) and in my consideration of whether the termination of each applicant, insofar as a valid reason is concerned was harsh,unjust or unreasonable, I find that the misapplication of the PER rating system as revealed earlier in these Findings, reveals that the termination of employment of each applicant was harsh,unjust and unreasonable.
This finding has been made on the grounds that I do not accept that Pacific Coal had reasonable grounds, on the facts available at the relevant time, capable of attracting the description as to what would be considered genuine operational requirements of its business for terminating the employment of the applicants. When all of the actions of Pacific Coal are considered in the context of what would be the normally accepted description of that which could be reasonably held to be the required connection within the operational requirements vehicle, when considered in context with my earlier Findings, such does not withstand scrutiny.
_ Consistent with the above I find that what Pacific Coal sought to rely upon as a defence for its actions based upon the alleged facts (and that is all that they could be described as) at the relevant time, in its selection of each of the applicants for termination of employment based upon its operational requirements claim, does not stand up to scrutiny.
_ I find that the alleged facts were so inaccurate that reliance by Pacific Coal upon such could only be perceived as creating a result representative of an unjust and unreasonable outcome for the applicants. This is revealed when consideration of the bastardised manner under which the applicants were rated and ranked as opposed to others in the workforce is revealed within my earlier Findings.
_ The extent of this is that such ratings and ultimate rankings were so inaccurate that the decision to terminate each of the applicants could never attract as a defence that such was a sound, defensible or well founded decision and to that extent consistent with my earlier Findings, I find the termination of employment of each of the applicants to have been capricious, spiteful and prejudiced.
[189] The above findings are of such an order that there was a compelling case made out that each of the applicants were denied a fair go all round when consideration of all of the relevant circumstances as have been made above within the submissions and the Findings are considered.
[190] Such is a factor properly to be taken into account in determining whether the termination was harsh, unjust or unreasonable, particularly when section 170CA(2) as raised in National Jet Systems Pty Ltd v Mollinger [Print R3130] enjoins the Commission to apply basic notions of fairness in carrying out its functions. To that extent the only logical conclusion is that the termination of each of the applicants, given the extent to which such denial of a "fair go all round" occurred, and in consideration of section 170CG(3), reveals that each applicant's termination of employment was harsh, unjust and unreasonable.
Remedy
[191] Having made the above findings I now turn to the question of remedy, and the need to have regard to that provided for under section 170CH of the Act - Remedies on Arbitration:
"(1) Subject to this section, the Commission may, on completion of the arbitration, make an order that provides for a remedy of a kind referred to in subsection (3), (4) or (6) if it has determined that the termination was harsh, unjust or unreasonable".
[192] In having determined that the termination of the employment of each of the applicants was harsh, unjust or unreasonable, consistent with Australian Meat Holdings Pty Ltd v McLauchlan [Print Q1625], where the Full Bench of this Commission (Ross VP, Polites SDP, Hoffman C) observed that:
"Given the broad nature of the discretion in ss170CH(3) and (6) we think that the question of whether reinstatement is `appropriate' in a particular case will be a matter for the judgment of the Commission member at first instance".
I have had regard to subsections 170CH(3) and (4) as to the appropriate remedy in light of such findings.
[193] From my assessment of the evidence and material before the Commission which led to the above findings in my judgment and having had regard to subsection 170CH(2), I am satisfied in all of the circumstances that reinstatement is appropriate for each of the applicants.
[194] I have therefore had regard to the provisions of subsection 170CH(2) of the Act:
"(2) The Commission must not make an order under subsection (1) unless the Commission is satisfied, having regarding to all the circumstances of the case including:
(a) the effect of the order on the viability of the employer's undertaking, establishment or service; and
(b) the length of the employee's service with the employer; and
(c) the remuneration that the employee would have received, or would have been likely to receive, if the employee's employment had not been terminated; and
(d) the efforts of the employee (if any) to mitigate the loss suffered by the employee as a result of the termination; and
(e) any other matter that the Commission considers relevant;
that the remedy ordered is appropriate".
[195] Having found that the termination of the employment of each of the applicants was harsh, unjust or unreasonable, I am satisfied, having had regard to subsection 170CH(3), that the appropriate remedy in that regard as to each of the applicants is that each applicant should be reinstated and awarded lost remuneration which each applicant would have received or would have been likely to receive if his employment had not been terminated.
[196] In reaching this conclusion I have had regard to each of the factors identified in section 170CH(2) to which I have referred earlier. After having considered, consistent with the Full Bench decision in Henderson and Department of Defence [Print S8591), 28 July 2000 (Giudice J, Williams SDP and Huxter C) having regard to section 170CH(6), I am satisfied that it is not inappropriate to reinstate the applicants.
[197] I am also satisfied that as there is no evidence before the Commission that indicates whether any of the dismissed applicants' former position is vacant or not and that such makes it possible for the Commission to make an order under subsection 170CH(3)(a), and in the alternative, under subsection 170CH(3)(b). By way of clarification, this Commission orders that each of the applicants be reinstated to his former position on and from 9 April or, if that is not available, to another like position on terms and conditions no less favourable than those on which he was previously employed. (See Yousif v MM Cables Energy Products [Print R2805], Cargill C).
[198] In this regard the unavailability of a position vacancy does not provide the basis for refusing to order reinstatement.(See Smith and Roulston v Capral Aluminium [Print R9808] Whelan C.
[199] Having had regard to all of the circumstances and consistent with subsection 170CH(2) of the Act:
"(a) the effect of the order on the viability of the employer's undertaking, establishment or service;"
I am satisfied, having had regard to section 170CH(2) and relevantly conclude that the effect of an order providing reinstatement for each of the applicants will not have an effect upon the viability of the Pacific Coal undertaking, establishment or service given the evidence raised upon this question and referred to earlier as to the performance of the Blair Athol mine; and as to:
"(b) the length of the employee's service with the employer;"
I have had regard to the length of service of each of the applicants relevantly revealing as it does that the length of employment of each of the applicant ranges from ten to eighteen years and accordingly could be viewed as long term and indicative of employees trained and skilled in the nature of the enterprise; and as to:
"(c) the remuneration that the employee would have received, or would have been likely to receive, if the employee's employment had not been terminated;"
This is addressed relevantly to the extent that such loss of remuneration should be made to the extent of the loss of the remuneration to each of the applicants during the period from the time of the individual termination of each applicant until the time of individual reinstatement subject to adjustment for income as is identifiable as to income earned during the relevant period including redundancy payments and other accrued entitlements; and as to
"(d) the efforts of the employee (if any) to mitigate the loss suffered by the employee as a result of the termination;"
I accept on the basis of the evidence and submissions relevantly made on behalf of the applicants I have had regard to the fact that the applicants have attempted to mitigate their losses consistent with each of the individual applicants' obligations in that regard; and as to:
"(e) any other matter that the Commission considers relevant;"
Having had regard to this element of section 170CH(6) and relevantly, I have formed the view that not to reinstate the applicants would compound the harsh, unjust and unreasonable effects of their terminations as this would simply leave the applicants to, in effect, wither on the vine in a location with little long term employment opportunities. Based upon the evidence at the time of these proceedings the applicants have continued to reside in the area of the mine which is an area where regular employment opportunities are limited other than at the Blair Athol mine.
In view of the length of service of each of the applicants, I am satisfied that to deny them the opportunity to look forward to completing their working lives at the Blair Athol mine which, given the length of each of their respective employment would not be an unreasonable expectation, and given the life expectancy of the mine would, in all of the circumstances, be inappropriate.
I am also satisfied, having had relevant regard to section 170CH(7), that the remedy I have determined is appropriate.
[200] Having made the above finding as to remedy, this Commission orders the reinstatement each of the applicants from 9 April 2001, without loss of continuity of employment and also orders payment for remuneration lost by each applicant since the date of termination up until the date of actual reinstatement of employment or the date upon which lost remuneration payment is made, whichever event first occurs.
[201] I am aware that there will be some adjustments because of various applicants having gained income in the relevant period. Additionally, I am conscious that all of the applicants received redundancy payments and other accrued leave entitlements or benefits and that these moneys will also need to be taken into account in arriving at the amount of remuneration lost.
[202] Further, I direct the parties to settle the draft orders necessary within 21 days of the date of issue of this decision as to the amount of remuneration lost for each applicant within the period described above and failure to reach agreement between the parties upon such amount of remuneration will, on notification to this Commission, cause a relisting of these matters for the purpose of a determination of the amounts, subject to the submissions of the parties.
BY THE COMMISSION:
COMMISSIONER
Appearances:
Mr Docking, of Counsel with Ms Doust of the Construction, Forestry, Mining and Energy Union for the applicants.
Mr Allen with Mr Longland for Pacific Coal Pty Ltd.
Hearing details:
1998.
Brisbane:
November 11.
1999.
Mackay:
February 8 to 11.
Brisbane:
February 15 to 19.
March 24 to 26.
April 14 to 16.
July 1 to 2 and 5 to 9.
September 6 to 10.
November 15 to 19 and 29 to 30.
December 1 to 2.
Decision Summary
Termination of employment - unfair dismissal - redundancy procedural fairness - contract of employment - sixteen matters joined involving coal miners terminated between August and October 1998 from Blair Athol mine - all members of CFMEU who had not signed AWA's - preliminary issue - after hearings and written submissions concluded correspondence received from CFMEU raising new issues following High Court decision in Re Pacific Coal P/L & ors [2000] HCA 34 - applicants inferred this decision supported their proposition that "reduction of hands" clause as existed in award at time of entering into contracts of employment was incorporated in individual's contracts - respondent submitted applicants' letters of appointment fail to meet test of expressly importing term of award into employment contract, further Pacific Coal did not overturn relevant law as existed at time of original proceedings - Commission considered Pacific Coal and its effect on relevant law including weight to be given to dissenting decisions and concluded that matters should be decided on original submissions as law had not relevantly altered from that enunciated in Byrne & Frew [(1995) 185 CLR 410] - submissions - applicants argued process used to determine list of employees to be terminated was fatally flawed, that Personal Effectiveness Reviews (PER's) were unreasonably used, respondent breached seniority clauses in individual contracts of employment, preference given to AWA employees, and other grounds - also claimed use of blacklists including one listing employees "still to go" - respondents submitted PER's only one factor in Performance Appraisal (PA) leading to terminations and process used was open and fair - extensive evidence brought by both parties - allegations of false evidence - findings - lack of procedural fairness, flaws and inconsistencies in process, insufficient training of those involved in PER and PA processes - bias against applicants including use of blacklists - terminations harsh, unjust and unreasonable - not notified of real reason for termination - not satisfied valid reason for termination of applicants - claim of operational requirements does not stand up to scrutiny - terminations capricious, spiteful and prejudiced - remedy - satisfied reinstatement appropriate - parties to draft orders providing for reinstatement and payment for remuneration lost since terminations, after allowing for redundancy and other termination payments made. | ||||
Smith and ors v Pacific Coal P/L | ||||
U Nos 20854 - 68 & 20890 of 1998 |
Print PR902679 | |||
Hodder C |
Brisbane |
9 April 2001 |
Printed by authority of the Commonwealth Government Printer
<Price code N>
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