Cases1604427/2024

Claimant v B&M Retail Limited

21 August 2025Before Employment Judge ShotterWalesremote video

Outcome

Claimant fails

Individual claims

Unlawful Deduction from Wagesfailed

Tribunal found the claimant was not an employee or worker but a volunteer participating in a DWP-funded work experience scheme under Regulation 51 of the National Minimum Wage Regulations 2015. The tribunal therefore had no jurisdiction to hear the claim. In the alternative, even if he had been a worker, he would not have been entitled to national minimum wage as he was exempt under Regulation 51.

Facts

The claimant was referred by the DWP for an unpaid work experience placement with the respondent from 25 September to 25 October 2024 as part of the Jobcentre Plus Work Experience Programme. He participated voluntarily, continued to receive benefits, and was made aware the placement was unpaid. He was interviewed at the end but was unsuccessful in obtaining employment. He later claimed he was owed wages and holiday pay. The claimant did not attend the preliminary hearing.

Decision

The tribunal found the claimant was not an employee or worker but a volunteer participating in a DWP-funded scheme exempt under Regulation 51 of the National Minimum Wage Regulations 2015. There was no mutuality of obligation or contract between the claimant and respondent. The tribunal therefore had no jurisdiction to hear the claim for unlawful deduction of wages. In the alternative, even if he had been a worker, he would not have been entitled to national minimum wage.

Practical note

Participants in government-funded work experience schemes under Regulation 51 NMWR 2015 are not workers or employees and are not entitled to national minimum wage, provided the scheme meets statutory requirements and participation is voluntary.

Legal authorities cited

Statutes

National Minimum Wage Regulations 2015 Reg.52Employment and Training Act 1973 s.2National Minimum Wage Act 1998 s.3Apprenticeships, Skills, Children and Learning Act 2009 s.100Jobseekers Act 1995 s.17BNational Minimum Wage Act 1998 s.54National Minimum Wage Regulations 2015 Reg.51

Case details

Case number
1604427/2024
Decision date
21 August 2025
Hearing type
preliminary
Hearing days
1
Classification
contested

Respondent

Sector
retail
Represented
Yes
Rep type
lay rep

Employment details

Service
1 months

Claimant representation

Represented
No