Cases2218010/2024

Claimant v Conflict Armament Research Ltd

28 March 2025Before Employment Judge WyethLondon Centralremote video

Outcome

Claimant fails

Individual claims

Unfair Dismissaldismissed on withdrawal

Tribunal found it had no jurisdiction to hear the claim because the claimant was not working in Great Britain. She was a Canadian national living and working exclusively in Canada throughout her engagement, with only sporadic visits to the UK for training. There was no sufficiently strong connection with Great Britain to overcome the territorial pull of the place of work (Canada).

Harassment(sex)dismissed on withdrawal

Tribunal found it had no jurisdiction to hear the claim on the same territorial grounds as the unfair dismissal claim. The claimant worked and lived in Canada, was paid in Canadian dollars, was subject to Canadian tax regime, and had no sufficiently strong connection with Great Britain to bring the claim within the territorial scope of the Equality Act 2010.

Breach of Contractwithdrawn

Withdrawn by claimant after accepting that she had received two months' written notice (exceeding the one month required under her consultancy agreement) and there was therefore no breach of contract.

Facts

The claimant, a Canadian national, was engaged by a UK-registered company from May 2019 to December 2023 under successive consultancy agreements as an investigator tracking weapons in conflict zones. She worked exclusively from Canada, was paid in Canadian dollars, and visited the UK only around five times in four and a half years for training. She was dismissed on notice in December 2023 when the respondent disbanded the unit she headed, citing loss of funding.

Decision

The tribunal held it had no jurisdiction to hear the claimant's unfair dismissal and sex harassment claims because she was not working in Great Britain. As an expatriate worker living and working entirely in Canada, she failed to demonstrate the especially strong connection with Great Britain required to overcome the territorial pull of her place of work. The tribunal also found that even if jurisdiction existed, the claimant was self-employed, not an employee or worker.

Practical note

An expatriate worker living and working exclusively abroad for a UK company needs an especially strong connection with Great Britain to bring claims under UK employment legislation — merely working for a UK-registered employer is insufficient.

Legal authorities cited

Ready Mixed Concrete v Minister of Pensions [1968] 2 QB 497Lawson v Serco Ltd [2006] ICR 250Duncombe v Secretary of State for Children, Schools and Families (No.2) [2011] ICR 1312Ravat v Halliburton Manufacturing and Services Ltd [2012] ICR 389Jeffrey v British Council [2019] IRLR 123Pimlico Plumbers Ltd v Smith [2018] ICR 1511Uber BV v Aslam [2021] UKSC 5Autoclenz Ltd v Belcher [2011] UKSC 41

Statutes

Employment Rights Act 1996 s.230(1)Employment Rights Act 1996 s.230(3)Equality Act 2010 s.26Employment Rights Act 1996 s.94Equality Act 2010 s.83(2)(a)Employment Rights Act 1996 s.98

Case details

Case number
2218010/2024
Decision date
28 March 2025
Hearing type
preliminary
Hearing days
2
Classification
contested

Respondent

Sector
professional services
Represented
Yes
Rep type
barrister

Employment details

Role
Head of Enhanced Investigations Unit
Salary band
£50,000–£60,000
Service
5 years

Claimant representation

Represented
No