Cases2402605/2021

Claimant v Life's Great Group Limited

30 October 2024Before Employment Judge Mark ButlerManchesterremote video

Outcome

Unknown

Facts

The claimant was Managing Director and designated compliance officer (SMF16) for the respondent. In September 2020, potential FCA compliance breaches came to light concerning protection insurance sales. The claimant's responsibilities were restricted on 4 September 2020. On 14 September 2020, the respondent's CEO (Mr Hayes) met with the claimant and discussed two options: suspension/disciplinary action or taking annual leave and resigning as a 'good leaver'. The claimant took two weeks' annual leave. On 23 September 2020, without prejudice negotiations occurred. The claimant raised a grievance on 9 October 2020.

Decision

This was a preliminary hearing solely to determine whether the meeting of 14 September 2020 was protected by without prejudice privilege. The tribunal found that a clear dispute existed before the meeting, that Mr Hayes represented the respondent in exploring settlement parameters, and that the discussion did not amount to unambiguous impropriety. The meeting and its contents were therefore excluded as evidence by reason of privilege.

Practical note

Without prejudice privilege will protect preliminary settlement discussions exploring the outline of a potential deal, even where the representative needs board approval, provided there is an existing dispute and the discussions do not reach the high threshold of unambiguous impropriety.

Legal authorities cited

Woodward v Santander UK PLC [2010] IRLR 834Framlington Group Ltd v Barneston [2007] IRLR 598Portnykh v Nomura International PLC [2014] IRLR 251South Shropshire DC v Amos [1986] 1 WLR 1271

Statutes

Employment Rights Act 1996 s.111A

Case details

Case number
2402605/2021
Decision date
30 October 2024
Hearing type
preliminary
Hearing days
1
Classification
procedural

Respondent

Sector
financial services
Represented
Yes
Rep type
barrister

Employment details

Role
Managing Director

Claimant representation

Represented
Yes
Rep type
barrister