Cases2600471/2024

Claimant v Aspire Communications Limited

26 January 2025Before Employment Judge Robin BroughtonNottinghamremote video

Outcome

Claimant succeeds£4,037

Individual claims

Unlawful Deduction from Wagessucceeded

The tribunal found the claimant was contractually entitled to standard commission for sales made during employment but installed after termination. The respondent had agreed in October 2023 to pay such commission. The respondent's attempt to claw back accelerator commission from prior quarters was not contractually justified — there was a prior oral agreement to 'turn a blind eye' to such clawbacks, and the 2023 emails did not clearly or validly vary that agreement.

Facts

The claimant was a high-performing field sales account manager for a BT Local Business franchise. His contract stated he ceased to be eligible for commission on termination, but in October 2023 the respondent agreed to pay him standard commission for sales made before termination but installed afterwards. The respondent had previously agreed orally to 'turn a blind eye' to clawing back accelerator commission overpayments. After the claimant sent a solicitor's letter in December 2023, the respondent conducted a 'forensic' examination back to 2020 and sought to claw back thousands of pounds, refusing to pay outstanding commission. The claimant brought an unlawful deduction claim for commission on sales installed between December 2023 and August 2024.

Decision

The tribunal found the October 2023 agreement to pay post-termination commission was a legally binding contractual variation supported by consideration. The respondent's attempt to introduce clawback of prior accelerator commission was not contractually justified: the earlier oral agreement not to apply clawback had never been validly varied, the 2023 emails were vague and did not clearly communicate a change, and introducing clawback retrospectively would be a perverse exercise of discretion. The claim succeeded; the claimant was awarded £4,037.49 (being £4,638.57 less £601.08 for excess annual leave taken).

Practical note

An employer cannot unilaterally impose retrospective clawback of commission without clear contractual authority, especially where there has been a prior agreement (even oral) not to do so and the change would deprive the employee of substantial sums already earned and relied upon.

Award breakdown

Unpaid wages£4,037

Legal authorities cited

Attrill and ors v Dresdner Kleinwort Ltd and anor 2012 IRLR 553, QBDWilliams v Roffey Bros & Nicholls (Contractors Ltd) [1991] 1 QB 1Hershaw and ors v Sheffield City Council 2014 ICR 1120, EATGreg May (Carpet Fitters & Contractors) Limited v Dring 1990 ICR 118 EATRobertson v Blackstone Franks Investment Management Limited 1998 IRLR 376Autoclenz Ltd v Belcher and ors 2011 ICR 1157, SCHarlow v Artemis International Corporation Ltd 2008 IRLR 629, QBDRoyal National Lifeboat Institution v Bushaway 2005 IRLR 675, EATInvestors Compensation Scheme Ltd v West Bromwich Building Society (No.1) 1998 1 WLR 896, HLArnold v Britton and ors 2015 AC 1619, SCChartbrook Ltd and anor v Persimmon Homes Ltd and anor 2009 1 AC 1101, HLAdams and ors v British Airways plc 1996 IRLR 574, CAPeninsula Business Services Limited v Sweeney 2004 IRLR 49Murphy and ors v Enterprise-Liverpool Ltd ET Case No.2101706/06Sagar v H Ridehalgh and Son Ltd 1931 1 Ch 310, CA

Statutes

Employment Rights Act 1996 s.27Employment Rights Act 1996 s.23Employment Rights Act 1996 s.13

Case details

Case number
2600471/2024
Decision date
26 January 2025
Hearing type
full merits
Hearing days
1
Classification
contested

Respondent

Sector
telecoms
Represented
Yes
Rep type
barrister

Employment details

Role
Field Sales Account Manager
Service
5 years

Claimant representation

Represented
No