Cases2200423/2024

Claimant v Tradition Management Services Limited

19 May 2025Before Employment Judge MurdochLondon Centralremote video

Outcome

Claimant succeeds

Individual claims

Unfair Dismissalsucceeded

The tribunal found the dismissal procedurally unfair. The respondent conceded unfairness on procedural grounds. The claimant was not given a formal disciplinary hearing, was not informed of allegations, was not given opportunity to respond, and was not offered any right of appeal. The decision to dismiss by summary termination was outside the band of reasonable responses given the lack of clarity communicated to the claimant about what was prohibited, and the extensive deliberate breaches of ACAS Code.

Wrongful Dismissalsucceeded

The tribunal found the claimant's conduct did not amount to gross misconduct justifying summary dismissal. The claimant's failures (underplaying involvement, not seeking clarity) did not on their own or together constitute a fundamental breach. Other employees made similar mistakes but were not dismissed. The respondent had not made its position clear until November 2022. Notice pay for 17.5 weeks was therefore due.

Breach of Contractsucceeded

Relates to the notice pay claim above — claimant succeeded in recovering contractual notice pay of 17.5 weeks.

Facts

Claimant was a senior broker on Collateral Baskets Desk at a financial services firm. Between April 2021 and November 2022, various practices to mitigate Crest fines (splitting and switching trades) were used by the desk with claimant's knowledge and involvement. Respondent's policies on whether these practices were prohibited were unclear and inconsistently communicated. In November 2022, claimant and team were suspended and respondent instructed external lawyers (Greenberg Traurig) to investigate at cost exceeding £1m. In August 2023, CEO dismissed claimant summarily for gross misconduct following verbal briefing from investigators, without any disciplinary hearing or appeal.

Decision

Tribunal found dismissal procedurally unfair with extensive deliberate breaches of ACAS Code. Respondent failed to clearly communicate that Crest fine mitigation was prohibited until November 2022. Claimant not guilty of gross misconduct, so entitled to notice pay. However, claimant contributed 50% by lack of transparency and failing to seek clarity. Polkey reduction of 50% applied as fair dismissal would likely have occurred anyway after one month. 25% ACAS uplift applied. Respondent's counterclaim for signing bonus repayment dismissed. Remedy quantum to be determined at hearing in October 2025.

Practical note

Employers must clearly communicate policies, especially on complex regulatory compliance issues, and follow fair procedures even when an expensive external investigation has been conducted — dismissing summarily without a disciplinary hearing or appeal will result in unfair dismissal, substantial ACAS uplift, and potential notice pay liability.

Adjustments

Polkey reduction50%

50% chance that respondent would have dismissed the claimant in any event had a fair procedure been followed, which would have taken one month longer

Contributory fault50%

Claimant was not transparent about knowing internal splitting occurred, underplayed his role in Crest fine mitigation in Greenberg interview, and should have sought clarity from management

ACAS uplift+25%

Respondent breached ACAS Code extensively and deliberately: no disciplinary hearing, claimant not informed of problem, no opportunity to be accompanied, no appeal. Breaches were closer to total than partial and deliberate. Full 25% uplift applied.

Legal authorities cited

Foley v Post Office [2000] ICR 1283Burchell [1978] IRLR 379London Ambulance Service NHS Trust v Small [2009] IRLR 563Hill v Great Tey Primary School [2013] ICR 691Lawless v Print Plus [2010] 4 WLUK 420Ingram v Bristol Street Parts UKEAT/0601/06/CEALangston v Dept for Business UKEAT/0534/09/ZTRobert Whiting Designs Ltd v Lamb [1978] ICR 89Iceland Frozen Foods v Jones [1983] ICR 17Sainsbury's Supermarkets Ltd v Hitt [2003] ICR 111Polkey v A E Dayton Services Ltd [1988] ICR 142

Statutes

Employment Rights Act 1996 s.94Employment Rights Act 1996 s.98Employment Rights Act 1996 s.123(6)Trade Union and Labour Relations (Consolidation) Act 1992 s.207A(2)Employment Rights Act 1996 s.122(2)

Case details

Case number
2200423/2024
Decision date
19 May 2025
Hearing type
full merits
Hearing days
6
Classification
contested

Respondent

Sector
financial services
Represented
Yes
Rep type
barrister

Employment details

Role
Broker (latterly Desk Head on the Collateral Baskets Desk)
Salary band
£100,000+
Service
4 years

Claimant representation

Represented
Yes
Rep type
barrister