Cases2209500/2023

Claimant v Apple Retail UK Limited

30 May 2024Before Employment Judge G HodgsonLondon Central

Outcome

Claimant succeeds

Individual claims

Automatic Unfair Dismissaldismissed on withdrawal

The claimant withdrew his claim of automatic unfair dismissal under section 152 Trade Union and Labour Relations (Consolidation) Act 1992 at the hearing. The tribunal dismissed the claim on withdrawal with the claimant's consent.

Unfair Dismissalsucceeded

The tribunal found the dismissal was outside the band of reasonable responses. The investigation was seriously flawed, particularly regarding allegation two. The dismissing officer relied on a non-existent 'zero tolerance policy', failed to properly identify policy breaches, and incorrectly concluded both comments were discriminatory. There were no reasonable grounds for concluding the first allegation amounted to harassment or bullying when no complainant was offended, and the second comment was potentially a protected act (reporting possible positive discrimination) which was not considered at all.

Facts

The claimant, employed by Apple Retail UK as a 'Genius' for over 12 years with an unblemished record, was dismissed for two alleged incidents of misconduct. On 13 December 2022, he made an inappropriate joke to a Chinese colleague referencing disease, which she did not find offensive. On 16 December 2022, he repeated a colleague's account that adding Jamaican heritage to a CV had led to success after initial rejection. Neither incident resulted in a complaint from the person directly addressed. The investigation was seriously flawed, particularly confusing the dates and facts of the second allegation, and the dismissing officer applied a non-existent 'zero tolerance policy' rather than the actual harassment and bullying policies.

Decision

The tribunal found the dismissal unfair. The investigation was inadequate, particularly for the second allegation where the claimant was never properly asked about the actual incident. The dismissing officer had no reasonable grounds to conclude either comment was discriminatory, harassment, or bullying. The first comment, while inappropriate, did not offend anyone present. The second comment was potentially a protected act (reporting possible positive discrimination) which was never considered. The officer relied on a non-existent zero tolerance policy and failed to properly apply the actual policies or understand discrimination law.

Practical note

Employers must base disciplinary decisions on actual written policies, not assumed 'zero tolerance' approaches, and must properly investigate whether comments that might appear discriminatory could actually be protected acts under the Equality Act, particularly when an employee is reporting potential discrimination in recruitment processes.

Legal authorities cited

Sainsbury's Supermarkets Ltd v Hitt [2003] ICR 111BHS v Burchell [1978] IRLR 379Iceland Frozen Foods v Jones [1983] ICR 17Abernethy v Mott, Hay and Anderson [1974] ICR 323Taylor v OCS Group Limited 2006 ICR 1602 CASheffield Health and Social Care NHS Foundation Trust v Crabtree EAT/0331/09

Statutes

Employment Rights Act 1996 s.98Equality Act 2010 s.27Trade Union and Labour Relations (Consolidation) Act 1992 s.152

Case details

Case number
2209500/2023
Decision date
30 May 2024
Hearing type
full merits
Hearing days
5
Classification
contested

Respondent

Sector
retail
Represented
Yes
Rep type
barrister

Employment details

Role
Genius
Service
12 years

Claimant representation

Represented
Yes
Rep type
barrister