Cases3314658/2021

Claimant v COOP Group Recruitment Limited

28 October 2024Before Employment Judge E DaveyCambridgehybrid

Outcome

Partly successful£3,191

Individual claims

Unlawful Deduction from Wagesfailed

The tribunal found the claimant's hourly rate was £26 per hour which she conceded she was paid. The claimant alleged she should have been paid £32 per hour but provided no documentary evidence to support this. The only evidence of the hourly rate in the invoices and self-bill invoice/remittance documents detailed £26 per hour.

Holiday Paysucceeded

COOP Group Recruitment Limited operated a rolled up holiday pay scheme that was not sufficiently transparent and comprehensive because payslips did not show how much of wages represented holiday pay. The claimant was entitled to 5.6 weeks accrued but untaken holiday pay on termination for the leave year 2020-2021 calculated at £3,190.54 based on an average week's pay of £569.74.

Facts

The claimant was a district nurse working through two linked umbrella companies (Mutual Group Limited and COOP Group Recruitment Limited) who sub-contracted her to an employment agency (MSI) which placed her with NHS trusts. She worked from 26 August 2019 to 30 March 2021 at £26 per hour. She claimed she was underpaid and that rolled up holiday pay was unlawful. The original hearing proceeded in her absence due to eviction and was dismissed. She successfully applied for reconsideration. Mutual Group Limited went into compulsory liquidation in December 2023.

Decision

The tribunal granted reconsideration and found the claimant was dually employed by both umbrella companies with joint liability. As Mutual Group Limited is insolvent, COOP Group Recruitment Limited is liable for the full obligation. The tribunal dismissed the underpayment claim finding the claimant was paid her agreed rate of £26 per hour. The holiday pay claim succeeded because the rolled up holiday pay scheme was not sufficiently transparent. The tribunal awarded £3,190.54 for 5.6 weeks accrued but untaken holiday pay.

Practical note

Employment tribunals can recognize dual employment relationships where parties mutually agree and operate as linked entities with joint liability, but this does not permit claims for rates of pay not actually agreed or evidenced in the contract.

Award breakdown

Holiday pay£3,191

Legal authorities cited

Prison Officers Association and ors v Gough and anor EAT 0405/09Harpur Trust v Brazel [2022] UKSC 21Smith v AJ Morrisroes and Sons Ltd [2005] ICR 596Robinson-Steele v RD Retail Services Ltd [2006] ICR 932United Taxis Ltd v Comolly and anor [2023] EAT 93Hellyer Ltd v McLeod v Ors; Boston Deep Sea Fisheries Ltd v Wilson and Anor [1987] ICR 526Autoclenz Ltd v Belcher [2011] UKSC 41Laugher v Pointer 5 B & C 547Dacas v Brook Street Bureau (UK) Ltd [2004] IRLR 358Patel v Specsavers Optical Group Ltd EAT 0286/18Viasystems (Tyneside) Ltd v Thermal Transfer (Northern) Ltd [2005] IRLR 983Cairns v Visteon UK Ltd UKEAT/0494/06/JOJ

Statutes

Insolvency Act 1986 s.130(2)Working Time Regulations 1998 Regs 13, 13A, 14, 16ERA 1996 s.230ERA 1996 s.224ERA 1996 s.212

Case details

Case number
3314658/2021
Decision date
28 October 2024
Hearing type
reconsideration
Hearing days
3
Classification
contested

Respondent

Sector
professional services
Represented
No

Employment details

Role
District nurse
Service
2 years

Claimant representation

Represented
No