Cases2216966/2024

Claimant v HopeFull (SCIO)

2 May 2025Before Employment Judge JoffeLondon Centralhybrid

Outcome

Claimant fails

Individual claims

Direct Discrimination(sex)struck out

Tribunal found claimant was not an employee within meaning of Equality Act 2010 and therefore had no standing to bring discrimination claims. Tribunal also found no territorial jurisdiction as claimant worked entirely in Ukraine with insufficient connection to Great Britain.

Harassment(sex)struck out

Tribunal found claimant was not an employee within meaning of Equality Act 2010 and therefore had no standing to bring discrimination claims. Tribunal also found no territorial jurisdiction as claimant worked entirely in Ukraine with insufficient connection to Great Britain.

Facts

The claimant was a US citizen who volunteered with a Scottish-registered charity providing humanitarian aid in Ukraine between February and September 2023. She worked as a volunteer cooking and distributing pizzas, receiving accommodation and food but no monetary payment. She claimed that Mr Fisher orally promised her a £400 monthly stipend in July or August 2023, which the respondents denied. The claimant alleged sex discrimination and harassment.

Decision

The tribunal found that the claimant was not an employee within the meaning of the Equality Act 2010 because there was no contract of employment, no remuneration (accommodation and food were expenses not remuneration), and no mutuality of obligation. The tribunal also found it lacked territorial jurisdiction because the claimant worked entirely in Ukraine with insufficient connection to Great Britain and British employment law. All claims were dismissed.

Practical note

Volunteers working abroad for UK charities are not automatically protected by UK employment law; there must be genuine employment status and a sufficiently strong connection with Great Britain for tribunals to have jurisdiction.

Legal authorities cited

Keeble v British Coal Corporation [1997] IRLR 336South East Sheffield Citizens Advice Bureau v Grayson [2004] ICR 1138X v Mid Sussex Citizens Advice Bureau [2013] ICR 249Groom v Maritime and Coastguard Agency [2024] EAT 71Autoclenz Ltd v Belcher [2011] UKSC 41Lawson v Serco Ltd [2006] ICR 250Duncombe v Secretary of State for Children, Schools and Families (No.2) [2011] ICR 1312Ravat v Halliburton ManufacturingDhunna v Creditsights Ltd [2015] ICR 105Robertson v Bexley Community Centre [2003] IRLR 434Jivraj v Hashwani [2011] ICR 1004Bates van Winkelhof v Clyde and Co LLP [2014] ICR 730

Statutes

Employment Rights Act 1996 s.94Equality Act 2010 s.123Equality Act 2010 s.83

Case details

Case number
2216966/2024
Decision date
2 May 2025
Hearing type
preliminary
Hearing days
4
Classification
contested

Respondent

Sector
charity
Represented
Yes
Rep type
solicitor

Employment details

Role
Volunteer (disputed)
Service
7 months

Claimant representation

Represented
Yes
Rep type
lay rep