Cases2202013/2024

Claimant v OCS Security Limited

20 February 2025Before Employment Judge C LewisLondon Central

Outcome

Claimant succeeds

Individual claims

Unfair Dismissalsucceeded

The tribunal found the dismissal procedurally unfair because the respondent failed to interview the claimant's line manager (Mr Stride) formally at any stage despite him being the only significant witness and despite the claimant saying the agreement had been verbal. No reasonable employer would have failed to interview Mr Stride and explore the possibility of genuine misunderstanding given the wholly informal homeworking arrangements. This made the investigation inadequate under the Burchell test.

Facts

Claimant was Deputy Security Manager at QEII Conference Centre since December 2017. He had informal arrangement with his line manager Mr Stride to work from home occasionally, usually one day per week, agreed verbally and recorded only by calendar invite. In August 2023, claimant worked from his parents' home in Cornwall from 14-17 August. He said this had been agreed with Mr Stride; Mr Stride said it had been discussed but not agreed. Claimant missed meetings and did not respond to manager's emails during this period. After investigation, claimant was summarily dismissed for gross misconduct.

Decision

Tribunal found dismissal procedurally unfair because the respondent failed to formally interview Mr Stride despite him being the only significant witness and the claimant saying the agreement had been verbal. No reasonable employer would have failed to explore the possibility of genuine misunderstanding given the informal homeworking arrangements. Compensatory award subject to: 50% Polkey reduction; 20% ACAS uplift for procedural failures; 25% contributory fault reduction (tribunal found claimant did not actually work while in Cornwall). Basic award reduced 25% for conduct prior to dismissal.

Practical note

Employers conducting misconduct investigations must formally interview key witnesses even where the employee cannot provide written evidence of verbal agreements, especially where informal arrangements existed and genuine misunderstanding is possible.

Adjustments

Polkey reduction50%

50% chance the claimant would have been dismissed even if Mr Stride had been formally interviewed, as employer might still have been sceptical and concluded claimant was not working while in Cornwall

Contributory fault25%

Claimant failed to respond to manager's queries while in Cornwall and tribunal found he did not do any work in that period. This was culpable conduct contributing to dismissal. Reduction limited to 25% because 50% already deducted for Polkey

ACAS uplift+20%

Respondent breached ACAS Code by: (1) disciplinary invitation letter not containing sufficient detail of allegations; (2) unreasonable 7.5 month delay in hearing appeal (28 September 2023 appeal letter to 17 May 2024 outcome)

Legal authorities cited

London Ambulance Service NHS Trust v Small [2009] IRLR 563BHS v Burchell [1978] IRLR 379Polkey v A E Dayton Services Ltd [1988] ICR 142Sainsbury's Supermarkets Ltd v Hitt [2003] ICR 111Abernethy v Mott, Hay and Anderson [1974] ICR 323Boys and Girls Welfare Society v McDonald [1996] IRLR 129Sattar v Citybank NA [2020] IRLR 104Hewston v Ofsted [2023] IRLR 878

Statutes

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

Case details

Case number
2202013/2024
Decision date
20 February 2025
Hearing type
full merits
Hearing days
2
Classification
contested

Respondent

Sector
professional services
Represented
Yes
Rep type
barrister

Employment details

Role
Deputy Security Manager
Service
6 years

Claimant representation

Represented
Yes
Rep type
barrister