Cases4106799/2023

Claimant v Ecebs Limited

7 January 2025Before Employment Judge M RobisonScotlandhybrid

Outcome

Other

Individual claims

Unfair Dismissalnot determined

This preliminary hearing determined only whether there was a TUPE transfer. The substantive unfair dismissal claims have not yet been determined on their merits.

Failure to Inform & Consultnot determined

This preliminary hearing determined only whether there was a TUPE transfer. The substantive claim regarding failure to inform and consult under TUPE has not yet been determined on its merits.

Facts

On 4 August 2023, Unicard Limited acquired all share capital in Ecebs Limited from Visa Europe Limited. Ecebs was a software company providing smart electronic ticketing systems for public transport, and had been Unicard's principal competitor for 20 years. Immediately following the share acquisition, Unicard's CEO Sean Dickinson took over day-to-day management of Ecebs, implementing changes to terms and conditions, conducting collective consultation without involvement of Ecebs' general manager Russell McCullagh, and making operational decisions. Products were consolidated under Unicard branding and customers were migrated to Unicard platforms.

Decision

The tribunal found that there was a relevant TUPE transfer from Ecebs to Unicard on 4 August 2023. Although the transaction was a share sale (which does not usually trigger TUPE), the tribunal found that Unicard had stepped into the shoes of the employer by taking over day-to-day control of Ecebs' business from the date of acquisition. Key factors included Unicard's CEO immediately assuming all management functions, the sidelining of Ecebs' general manager, harmonisation of terms and conditions, consolidation of products and branding, and elimination of Ecebs as a competitor.

Practical note

A share acquisition can constitute a TUPE transfer where the purchasing company goes beyond normal parent-subsidiary oversight and assumes day-to-day operational control of the acquired business from the date of acquisition, effectively stepping into the shoes of the employer.

Legal authorities cited

Guvera Limited v Blinkbox Music UKEAT/0265/16Allen C-234/98 [2000] IRLR 119Brookes and others v Borough Care Services Ltd [1998] IRLR 636Millam v Print Factory (London) 1991 Ltd [2007] IRLRSmith and others v Jackson Lloyd UKEAT/0127ICAP Management Services v Berry [2017] IRLR 811

Statutes

TUPE Regulation 3(1)(a)Transfer of Undertakings (Protection of Employment) Regulations 2006

Case details

Case number
4106799/2023
Decision date
7 January 2025
Hearing type
preliminary
Hearing days
3
Classification
contested

Respondent

Sector
technology
Represented
Yes
Rep type
barrister

Employment details

Role
Various software development roles

Claimant representation

Represented
Yes
Rep type
barrister